GDPR·Article Article 5·critical·Component: Chapter II: Principles

What this control requires

Ensures personal data is processed lawfully, fairly, transparently, with purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability. This control addresses Data Governance.
— GDPR, Article Article 5

In plain English

Ensures personal data is processed lawfully, fairly, transparently, with purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability. In practice, this means you can prove you principles purpose limitation-level controls on a defined cadence.

Why it matters

GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.

This control is rated critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.

What an auditor looks for

A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.

Within Chapter II: Principles, the assessor will trace your implementation back to the catalogue reference (Article Article 5) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Principles. Document the trigger, the owner and the cadence.
  • Data. Document the trigger, the owner and the cadence.
  • Confidentiality. Document the trigger, the owner and the cadence.
  • Scope: purpose limitation, principles relating to processing of personal data.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.
  • Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Principles relating to processing of personal data.

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in GDPR

References

Topics: governance riskpolicy managementprivacy management