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What does “storage limitation” mean under EU Data Protection law?

This is the very beautiful Long Room Library at Trinity College Dublin. — 1885 — National Library of Ireland
  1. Lawfulness, fairness and transparency
  2. Purpose limitation
  3. Data minimization
  4. Accuracy
  5. Storage limitation
  6. Integrity and confidentiality (security)
  7. Accountability

Article 5 of GDPR

(1) Personal data shall be:

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);

The principle of “storage limitation”

  • It is important to note that there is a difference between permanently deleting personal data and taking it offline. If personal data is stored offline, this should reduce its availability and the risk of misuse or mistake but it still constitutes processing. Storing it offline is only permitted under EU data protection law where the entity has a valid purpose for holding the data.
  • Personal data that has been pseudonymised — eg key-coded — will usually still permit identification Therefore, although it may be a valid tool for compliance with data minimisation and security, it does not equate erasure for the purposes of storage limitation.

What is a ‘retention policy’?

What is new under GDPR?

Changes from Directive to GDPR

ICO Checklist

Consequences of non-compliance

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