Test Secondary Use Before Reusing Data
Apply purpose-compatibility thinking before reusing personal data for a new operational or analytics purpose.
Secondary use needs a bridge. The bridge is not "we already have the data." It is a compatibility assessment. Five checks Ask: How close is the new purpose to the original one? What was the relationship and expectation at collection? Is the data sensitive or revealing? What could happen to the person? What safeguards narrow the risk? Why this works The check forces teams to separate low-risk operational learning from a new decision system. It also creates evidence that the team noticed the change in purpose and made a reasoned call. The advanced move Do not over-lawyer every small reuse,…
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