Governance and inventory

Separate materially distinct purposes

Detect an activity carrying several materially distinct purposes or lawful bases and separate it into independently governed activities, preserving the links that still apply.

A single activity called "Customer data processing" often turns out, on inspection, to cover order fulfilment under contract and marketing analytics under legitimate interests. The two cannot share one lawful basis, one notice or one retention rule, so they cannot share one record either.

This use case is exercised when a reviewer reads the purpose statement of an existing activity at Aldergate Retail and finds the second purpose hiding inside it.

The outcome proves that separating a record does not lose the links already made, only narrows what each resulting activity is responsible for.

Regulation

Articles 5(1)(b), 6 and 6(4)

Registers

Processing activity · Privacy notice · Consent record

The steps

1. 01Open the Processing activities register and select the activity in question.
2. 02Read the purpose statement and the lawful basis held on the Details tab.
3. 03Use the plus button beside the register title to create a second activity for the distinct purpose.
4. 04Open the Context tab of the new activity and use "Link a record" to attach the data subject sets, systems and measures that apply to both purposes.
5. 05Return to the original activity, narrow its purpose statement on the Details tab to the remaining purpose alone.
6. 06Open the privacy notice linked to the original activity and revise it to describe both activities separately, or split it in the same way.