In today’s data-driven economy, personal data has become a valuable commodity—and a serious liability. With the introduction of the General Data Protection Regulation (GDPR), businesses across Europe (and globally) have had to rethink the way they collect, store, and use customer data. One of the core principles embedded in GDPR is data minimisation—a requirement that businesses must collect only the data that is adequate, relevant, and limited to what is necessary for the intended purpose.
This sounds simple in theory, but what does it look like in practice? In this article, we’ll explore five of the best real-world examples of data minimisation in action, how organizations have implemented these practices, and why they matter. These examples span different industries and demonstrate how effective data minimisation can reduce risk, increase customer trust, and ensure GDPR compliance.
What Is Data Minimisation Under GDPR?
Before diving into examples, let’s briefly clarify what data minimisation means in the context of GDPR.
Definition
Article 5(1)(c) of GDPR defines data minimisation as the principle that:
“Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.”
In plain terms, this means you:
- Should not collect more personal data than you need.
- Must justify the necessity of every data point you collect.
- Need to routinely review and delete any data that no longer serves a valid purpose.
Why Data Minimisation Matters
- Reduces security risks: Less data means less to protect.
- Builds trust: Consumers are increasingly wary of businesses collecting too much personal information.
- Saves costs: Data storage and protection cost money.
- Ensures GDPR compliance: Avoids fines of up to €20 million or 4% of global turnover.
Now, let’s break down the five best data minimisation GDPR examples that demonstrate how to implement this principle effectively.
1. Apple’s “Sign in with Apple” Feature: Only What’s Necessary
Apple has long emphasized privacy as a core value, and its “Sign in with Apple” feature offers one of the clearest examples of data minimisation in a real-world tech product.
How It Works:
When users sign up for an app or service using “Sign in with Apple,” they’re given the option to hide their email address. Apple then creates a unique, random forwarding email address, allowing users to sign up anonymously.
GDPR Data Minimisation in Action:
- Only essential data shared: The app gets just what it needs to create a user account—no more.
- No unnecessary email tracking: The forwarded email shields the user’s real identity.
- Data decoupling: Prevents apps from linking users across platforms using their email.
Key Benefits:
- Empowers users to control their personal data.
- Reduces the risk of data misuse and identity linking.
- Excellent compliance with purpose limitation and data minimisation principles.
2. European Banks’ KYC (Know Your Customer) Protocols: Risk-Based Minimalism
The financial industry is notorious for strict regulations, especially regarding Know Your Customer (KYC) rules. However, GDPR has pushed banks to rethink how much data they gather—even for something as critical as identity verification.
The Issue:
KYC procedures require collecting personal documents to comply with anti-money laundering laws. But GDPR insists that even legally required data collection must be proportionate.
Example:
Several European banks now implement tiered KYC processes based on customer risk levels. For example:
- Low-risk account: Only requires basic ID and address confirmation.
- High-risk accounts or services: Additional data like source of income or proof of funds.
GDPR Data Minimisation in Action:
- Risk-based approach avoids a one-size-fits-all policy.
- Just-in-time data collection: Only ask for more data when it’s truly necessary.
- Regular reviews to ensure old or unnecessary documents are deleted.
Key Benefits:
- Meets both AML and GDPR compliance.
- Minimises data exposure and reduces breach liability.
- Builds customer trust through transparency.
3. DuckDuckGo: Privacy by Design, Search Engine with No Tracking
While giants like Google collect mountains of personal data to serve ads, DuckDuckGo takes the opposite approach—by design. It’s a privacy-first search engine that collects no personal data at all.
How It Works:
- No IP address logging.
- No cookies or device fingerprinting.
- No user profiling or history-based personalization.
GDPR Data Minimisation in Action:
- Data avoidance as a strategy: The best way to minimise data is to not collect it at all.
- No identifiers stored, so even if the service is hacked, there’s nothing personal to steal.
Key Benefits:
- Ultimate form of data minimisation.
- Helps users retain full control over their privacy.
- Great example of GDPR’s privacy by design ethos.
4. Job Application Platforms: Optional Demographics & Sensitive Data Fields
Recruitment platforms have had to make significant changes post-GDPR. One particular area of concern is the collection of sensitive personal data—such as age, gender, ethnicity, or even disabilities.
Best Practice Example:
Modern platforms like Workable and Greenhouse allow candidates to opt-in to provide demographic data, with clear statements explaining how and why the data may be used (e.g., for diversity reporting).
GDPR Data Minimisation in Action:
- Fields not required for job application are clearly marked as optional.
- No profiling decisions made based on this data unless explicitly consented.
- In some platforms, anonymised data is automatically deleted after a retention period.
Key Benefits:
- Prevents indirect discrimination.
- Supports diversity goals without compromising privacy.
- Ensures sensitive data is collected ethically and legally.
5. E-Commerce Sites with Guest Checkout: No Account, No Problem
Many online retailers used to force users to create accounts for every purchase, collecting names, addresses, emails, phone numbers, and even birthdays.
That changed with GDPR.
Example:
Retailers like Zalando or IKEA now offer guest checkout options, allowing users to make purchases without creating an account.
GDPR Data Minimisation in Action:
- Only transactional data collected: Name, shipping address, and payment info.
- No long-term storage unless the customer consents to create an account.
- Email is used only for transactional communication unless otherwise opted-in.
Key Benefits:
- Reduces long-term storage of customer data.
- Makes compliance with data retention and data subject access requests (DSARs) easier.
- Encourages customer trust through simplicity and transparency.
Additional Tips for Implementing Data Minimisation
Even if your business doesn’t match the examples above, you can still practice effective data minimisation. Here are some actionable tips:
1. Conduct Regular Data Audits
- Review what data is being collected, where it’s stored, and why.
- Delete unnecessary or outdated records.
2. Use Consent-Based Fields
- Only collect data with explicit user consent.
- Mark optional fields clearly in forms.
3. Apply Just-In-Time Data Collection
- Ask for data only when needed in a process.
- Don’t collect everything upfront unless required.
4. Limit Internal Access
- Not all employees need access to all personal data.
- Apply role-based permissions.
5. Monitor and Train Teams
- Employees should understand the principle of least privilege.
- Provide training on GDPR compliance and data minimisation.
Common Data Minimisation Mistakes to Avoid
Understanding best practices is only half the battle. Avoiding common pitfalls is just as important.
❌ Collecting “Just in Case” Data
Don’t ask for information you might need in the future—GDPR requires present necessity.
❌ Excessive Form Fields
A 15-field signup form for a newsletter? That’s a red flag.
❌ Storing Data Indefinitely
Unless you have a legal requirement or ongoing user relationship, you must set deletion policies.
❌ Not Anonymising Data
If data can be anonymised without affecting your business goals—do it.
Final Thoughts: Why Data Minimisation Is the Future
Data minimisation isn’t just a checkbox on a compliance form. It’s a mindset—a smarter, safer way to do business in the digital age.
In a world of ever-increasing data breaches, surveillance fears, and tightening privacy laws, companies that embrace data minimisation:
- Win trust.
- Reduce liability.
- Stay ahead of regulations.
From Apple’s clever use of anonymised email addresses to DuckDuckGo’s refusal to track anyone at all, these examples show that data minimisation can be practical, powerful, and profitable.
Whether you’re a startup or a multinational corporation, implementing GDPR-compliant data minimisation practices will set you up for long-term success in the privacy-first economy.