Looking to Canada for input on the GDPR’s data retention requirements
One of the core principles of data processing set forth in Article 5(e) of the EU General Data Protection Regulation is that personal data shall be retained in a form that “permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.” Although this language is not complex, it raises critical questions not answered within the text, namely: What comprises a purpose and how does one determine whether the purpose is resolved?
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