Privacy-Preserving Data Practices & Minimization Checklist

Project name / ID

Enter the project name or identifier so this checklist can be linked to project records.

Data owner / responsible person

Who will be accountable for data minimization and privacy controls for this project?

Scope & lawful basis checkpoints

Confirm the project scope and legal basis for processing. Check applicable items.

Purpose is documented and narrowly defined

Lawful basis for processing recorded (consent, contract, legitimate interest, etc.)

Data attributes limited to what is necessary for purpose

Direct identifiers are avoided or removed where possible

Pseudonymization & transformation techniques

Select techniques applied or planned. Provide details in Notes where unusual choices are made.

Direct identifiers replaced with pseudonyms (mapping stored separately)

Irreversible hashing used where re-identification is not required

Mapping tables are encrypted and access-controlled

Format-preserving encryption used where necessary for schemas

Tokenization used for sensitive tokens (SSNs, payment data)

Feature & sampling minimization

Check the practical steps taken to reduce data footprint while preserving model utility.

Feature selection or dimensionality reduction planned/applied

Representative or stratified sampling used instead of full dataset

Synthetic or derived datasets used where feasible

Testing performed on de-identified or pseudonymized data

Retention, storage & access controls

Establish clear retention periods, storage controls, and access limitations.

Retention periods defined per data category and documented

Automated deletion or disposal mechanisms planned

Encryption at rest and in transit enabled

Access is granted on a least-privilege basis and logged

Access and processing are logged for auditability

Legal, contracts & third-party processing

Confirm contractual and vendor safeguards where third parties are involved.

Data processing agreements in place with third parties

Vendor security and privacy reviewed

Cross-border data transfer controls documented

Privacy risk level

Select the project's assessed privacy risk level. High-risk projects may require a DPIA or senior sign-off.

Low

Medium

High (DPIA recommended/required)

Does this project require a Data Protection Impact Assessment (DPIA)?

Answer yes if processing is systematic, large-scale profiling, involves special categories of data, or otherwise triggers statutory DPIA requirements.

Required artifacts (attach or link in project record)

Ensure these artifacts are created and attached to the project record for sign-off.

Data flow map

Data mapping / inventory

Retention schedule

DPIA (if required)

Access control list and roles

Privacy review sign-off checklist

Complete these actions to finalize the privacy review and sign-off.

Privacy review completed by reviewer/team

Residual risks and mitigations documented

Formal sign-off recorded with name and date

Sign-off name (privacy reviewer or approver)

Name of the person approving the privacy review.

Sign-off date

Date of approval (YYYY-MM-DD).

Notes, open questions, or deviations

Use this field to explain any unchecked items, remaining risks, or actions to complete.

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Privacy-Preserving Data Practices & Minimization Checklist

Privacy-Preserving Data Practices & Minimization Checklist

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