Article 5: Principles relating to processing of personal data

To meet the article 5: principles relating to processing of personal data requirement, you must translate GDPR’s data processing principles into day-to-day controls for every processing activity, then keep evidence that those controls run. Focus on purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality, transparency, and accountability. (Regulation (EU) 2016/679, Article 5)

Key takeaways:

• Turn each Article 5 principle into control statements tied to specific systems, datasets, and owners. (Regulation (EU) 2016/679, Article 5)
• Prove “accountability” with auditable artifacts: decisions, approvals, logs, exceptions, and remediation records. (Regulation (EU) 2016/679, Article 5)
• Start with a role-and-scope register (controller vs processor) so you don’t design controls for the wrong obligation set. (Regulation (EU) 2016/679)

Article 5 is the operator’s checklist for GDPR processing hygiene. Regulators and customers will often treat it as a “show me your basics” test: do you process personal data for defined purposes, keep only what you need, keep it correct, delete it when you should, secure it, and can you prove all of that on demand. (Regulation (EU) 2016/679, Article 5)

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing Article 5 is to stop treating it as a policy paragraph and treat it as a control map. You want each principle to have: (1) a clear operational owner, (2) a trigger (new product, new dataset, new third party, new integration), (3) the workflow steps the business must follow, and (4) the evidence you retain to defend decisions later. (Regulation (EU) 2016/679, Article 5)

This page gives requirement-level implementation guidance you can put into a procedure and audit program immediately. It also highlights a common failure mode: teams document principles but cannot connect them to specific processing activities, systems, retention schedules, and access paths. That gap is where accountability breaks. (Regulation (EU) 2016/679, Article 5)

Regulatory text

Excerpt (provided): “1. Personal data shall be:” (Regulation (EU) 2016/679, Article 5)

What the operator must do with this text: Article 5(1) sets out the principles that must govern all processing of personal data; Article 5(2) adds accountability, meaning you must be able to demonstrate compliance with those principles. Practically, you need controls embedded across the lifecycle: intake/collection, use, sharing, storage, retention/deletion, and security operations, with evidence you can produce quickly. (Regulation (EU) 2016/679, Article 5)

Operational translation of Article 5 principles (control intent):

• Lawfulness, fairness, transparency: Define and document why you process, what you tell people, and how you avoid deceptive or unexpected uses. (Regulation (EU) 2016/679, Article 5)
• Purpose limitation: Bind data to specific, approved purposes and prevent secondary use drift. (Regulation (EU) 2016/679, Article 5)
• Data minimisation: Collect and keep only what is necessary for the stated purpose. (Regulation (EU) 2016/679, Article 5)
• Accuracy: Keep data accurate and provide correction/update paths. (Regulation (EU) 2016/679, Article 5)
• Storage limitation: Define retention and enforce deletion or de-identification when the purpose ends. (Regulation (EU) 2016/679, Article 5)
• Integrity and confidentiality: Apply appropriate security controls to protect personal data. (Regulation (EU) 2016/679, Article 5)
• Accountability: Keep proof: decisions, approvals, training, monitoring, exceptions, and remediation. (Regulation (EU) 2016/679, Article 5)

Plain-English interpretation (what Article 5 demands)

You must run your personal data processing like a governed system, not an ad hoc set of product decisions. Each dataset needs a reason to exist, a defined use, a limited set of fields, a quality standard, a retention rule, and security protections. Then you need to show a regulator or auditor the paperwork and system evidence that confirms those rules are real. (Regulation (EU) 2016/679, Article 5)

Accountability is the practical “teeth” of Article 5. Many programs have “principles” in a privacy policy, but can’t answer basic questions like: “Where is this data stored?”, “Who can access it?”, “Why do we need this field?”, “When do we delete it?”, “Which third parties receive it?” Article 5 expects you to answer those quickly and consistently. (Regulation (EU) 2016/679, Article 5)

Who it applies to (entity and operational context)

Entities: Any organization processing personal data in scope of GDPR, including those acting as controllers or processors; what you must do in practice depends on your role per processing activity. (Regulation (EU) 2016/679)

Operational contexts where Article 5 becomes urgent:

• New product features that add tracking, profiling, or behavioral analytics (purpose limitation and transparency pressure). (Regulation (EU) 2016/679, Article 5)
• Data integrations (ETL pipelines, CDPs, CRMs) that replicate data and complicate storage limitation and access control. (Regulation (EU) 2016/679, Article 5)
• Third party sharing (SaaS tools, support platforms, marketing vendors) that creates secondary use and retention risk. (Regulation (EU) 2016/679, Article 5)
• M&A / system consolidation where legacy retention and access rules become inconsistent. (Regulation (EU) 2016/679, Article 5)

What you actually need to do (step-by-step)

Step 1: Establish role-and-scope for every processing activity

Create a simple register that ties each processing activity to:

• Controller vs processor role (and joint controller if applicable)
• Business owner
• Data categories and data subjects
• Systems where data is stored/processed
• Key third parties receiving data This prevents a common risk factor: building controls without a clear role decision and scope. (Regulation (EU) 2016/679)

Practical tip: Put this register behind your change intake process so new tools and integrations cannot go live without an entry and owner approval.

Step 2: Convert principles into control statements you can test

Write control statements per principle, phrased so Internal Audit or a regulator could test them. Example format:

Principle	Testable control statement	Typical system evidence
Purpose limitation	Each dataset has an approved purpose, and downstream uses require documented review/approval.	Data inventory entry, change ticket approval, DPIA/assessment record where used
Data minimisation	New data fields require justification and owner approval; optional fields default to off unless needed.	Schema change PRs, data dictionary, product requirements
Storage limitation	Retention schedules exist and deletion jobs run; exceptions are documented and time-bound.	Retention policy, deletion logs, backup retention config, exception register
Integrity/confidentiality	Access is role-based; high-risk access is logged and reviewed; encryption is configured where needed.	Access control lists, IAM logs, security configs

Tie each statement to an owner and a cadence for review. (Regulation (EU) 2016/679, Article 5)

Step 3: Embed Article 5 into operational workflows (not a standalone policy)

Update the workflows teams already use:

• Product/engineering intake: Add privacy checkpoints for purpose, minimisation, retention, and transparency updates. (Regulation (EU) 2016/679, Article 5)
• Data/analytics requests: Require purpose and field-level justification; restrict raw exports; prefer aggregated views where possible. (Regulation (EU) 2016/679, Article 5)
• Third party onboarding: Require mapping of data shared, purpose, retention expectations, and security controls. (Regulation (EU) 2016/679, Article 5)
• Incident response: Make sure incident triage identifies impacted personal data sets and confirms access controls and logging were operating. (Regulation (EU) 2016/679, Article 5)
• Records of processing: Keep your processing documentation aligned with actual systems and sharing paths so transparency and accountability don’t drift. (Regulation (EU) 2016/679, Article 5)

Step 4: Build the “accountability evidence packet” per processing activity

For each material processing activity, retain a packet that includes:

• Role-and-scope decision (controller/processor) and owner sign-off (Regulation (EU) 2016/679)
• Purpose statement and approved uses (Regulation (EU) 2016/679, Article 5)
• Data dictionary (fields collected, required vs optional, source) (Regulation (EU) 2016/679, Article 5)
• Retention schedule + deletion method + proof of operation (Regulation (EU) 2016/679, Article 5)
• Access model and proof of access review/logging (Regulation (EU) 2016/679, Article 5)
• Third party sharing list and contracts/controls references (Regulation (EU) 2016/679, Article 5)
• Exceptions and compensating controls, with remediation tracking (Regulation (EU) 2016/679, Article 5)

This is where tools like Daydream fit naturally: you can standardize the evidence packet format, assign owners, track exceptions, and export a defensible audit bundle per processing activity without rebuilding the same narrative each quarter. (Regulation (EU) 2016/679, Article 5)

Step 5: Monitor drift and enforce change control

Article 5 failures often happen after launch. Set up:

• A periodic review of high-risk datasets and major third party flows
• Alerts for new data stores/buckets, new exports, and new integrations
• A documented exception process with expiry and re-approval triggers This is how you keep “purpose limitation” and “storage limitation” true over time. (Regulation (EU) 2016/679, Article 5)

Required evidence and artifacts to retain

Keep artifacts in a way you can produce quickly by system, dataset, or processing activity:

• Processing register with role decision, systems, categories, and owners (Regulation (EU) 2016/679)
• Requirement-specific operating procedure (who does what, when, and approvals) (Regulation (EU) 2016/679, Article 5)
• Data mapping / inventory outputs and data dictionaries (Regulation (EU) 2016/679, Article 5)
• Retention schedule, deletion run logs, and backup retention configurations (Regulation (EU) 2016/679, Article 5)
• Access reviews, RBAC policy, admin access list, and audit logs (Regulation (EU) 2016/679, Article 5)
• Exception register (what, why, compensating controls, expiry, approver) (Regulation (EU) 2016/679, Article 5)
• Third party data sharing register and due diligence outputs relevant to integrity/confidentiality (Regulation (EU) 2016/679, Article 5)

Common exam/audit questions and hangups

Expect questions framed as “demonstrate”:

• Show the approved purpose and where it is enforced in systems. (Regulation (EU) 2016/679, Article 5)
• Show your rationale for collecting each data field (especially sensitive or high-risk fields). (Regulation (EU) 2016/679, Article 5)
• Show retention rules and proof that deletion occurs across production, logs, and backups where applicable. (Regulation (EU) 2016/679, Article 5)
• Show how you keep data accurate and how corrections propagate to downstream systems. (Regulation (EU) 2016/679, Article 5)
• Show access control design and evidence of access monitoring/review. (Regulation (EU) 2016/679, Article 5)

Hangups that stall audits:

• No single owner per processing activity.
• “Retention policy exists” but no deletion evidence.
• Shadow IT tools that receive exports and create unmanaged copies. (Regulation (EU) 2016/679, Article 5)

Frequent implementation mistakes (and how to avoid them)

• Mistake: Writing one global principle statement and calling it done.
  Fix: map principles to each processing activity and require an evidence packet. (Regulation (EU) 2016/679, Article 5)

• Mistake: Treating minimisation as “collect less,” but not controlling downstream replication.
  Fix: control exports, limit raw access, and document where copies exist. (Regulation (EU) 2016/679, Article 5)

• Mistake: Retention schedules that ignore derived datasets and logs.
  Fix: include analytics tables, event logs, tickets, call recordings, and backups in retention design and evidence. (Regulation (EU) 2016/679, Article 5)

• Mistake: No exception discipline.
  Fix: require expiry, compensating controls, and re-approval triggers for exceptions. (Regulation (EU) 2016/679, Article 5)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement page, so this section is omitted per your rules.

From an operational risk view, Article 5 failures tend to increase exposure in three ways: (1) broader-than-necessary data footprint (breach impact and incident scope), (2) indefensible processing rationale (complaints and regulator scrutiny), and (3) inability to demonstrate control operation (accountability gap). Treat “demonstrate compliance” as a standing readiness requirement, not an ad hoc audit scramble. (Regulation (EU) 2016/679, Article 5)

Practical execution plan (30/60/90-day)

Your rules prohibit citing timelines as elapsed-day implementation claims. Use these as phases you can scale to your operating tempo.

Phase 1: Immediate stabilization

• Stand up the role-and-scope register for in-scope processing activities, with named owners. (Regulation (EU) 2016/679)
• Pick the highest-risk processing activities (customer data platforms, marketing pipelines, support tooling, identity systems) and build initial evidence packets. (Regulation (EU) 2016/679, Article 5)
• Publish a requirement-specific operating procedure for Article 5 controls, approvals, and exceptions. (Regulation (EU) 2016/679, Article 5)

Phase 2: Near-term operationalization

• Add Article 5 checkpoints to intake: new product work, new datasets, and third party onboarding. (Regulation (EU) 2016/679, Article 5)
• Implement field-level minimisation controls: schema change approvals and data dictionary ownership. (Regulation (EU) 2016/679, Article 5)
• Formalize retention enforcement and deletion evidence collection across primary systems and derived datasets. (Regulation (EU) 2016/679, Article 5)

Phase 3: Ongoing assurance

• Schedule periodic reviews for data minimisation, retention exceptions, and access evidence. (Regulation (EU) 2016/679, Article 5)
• Measure drift: new integrations, new exports, new data stores; route them through approvals. (Regulation (EU) 2016/679, Article 5)
• Standardize your audit export: one-click bundles per processing activity (register entry, decisions, logs, exceptions, remediation). Daydream is well-suited to keep these packets consistent across teams and third parties. (Regulation (EU) 2016/679, Article 5)

Frequently Asked Questions

How do I “prove” purpose limitation in an engineering-driven organization?

Require a purpose statement and owner approval for each dataset and each material downstream use, then connect it to change control (tickets/PRs) and data access rules. Keep the approval trail in the evidence packet. (Regulation (EU) 2016/679, Article 5)

Does Article 5 apply to processors, or only controllers?

It applies across processing of personal data; obligations vary by role, so start by documenting whether you act as controller or processor for each processing activity. Your controls and evidence should match that role decision. (Regulation (EU) 2016/679)

What’s the minimum evidence an auditor will accept for storage limitation?

A retention schedule alone is weak; pair it with proof of enforcement such as deletion job logs, configuration screenshots/exports, and an exception register for items you cannot delete yet. Keep those artifacts tied to the specific system and dataset. (Regulation (EU) 2016/679, Article 5)

We have legacy systems that can’t delete individual records. How do we handle Article 5?

Document the limitation as an exception, define compensating controls (restricted access, segregation, reduced replication), and set a remediation plan with an owner. Make the exception time-bound and re-approved on a defined trigger. (Regulation (EU) 2016/679, Article 5)

How should third parties be handled under the integrity and confidentiality principle?

Maintain a list of third parties receiving personal data per processing activity, confirm security and retention expectations, and retain due diligence outputs and contract artifacts in the evidence packet. Ensure exports and sharing paths are tracked so shadow sharing does not bypass governance. (Regulation (EU) 2016/679, Article 5)

What should I operationalize first if I can only do one thing this quarter?

Build the role-and-scope register and evidence packets for the highest-risk processing activities. That single move forces clarity on purpose, minimisation, retention, security, and accountability, and it reduces audit scramble. (Regulation (EU) 2016/679, Article 5)