Engineering, production, governance, cost, communication · insight-0278
Minimise personal data in features and give training snapshots a retention period
- Evidence type
- documented fact
- Difficulty
- medium
- Roles
- ML engineer, Data scientist, Data analyst
- Industries
- telecom, banking, healthcare
Summary: situation, action, reason, boundary
Situation
A churn model's training set copies full customer records, including fields the model never uses, and snapshots are kept indefinitely.
Action
Select only the fields that features need, pseudonymise identifiers, store derived features rather than raw records where possible, and set and enforce retention periods for training snapshots and logs with your privacy team.
Reason
Under GDPR, personal data should be limited to what is necessary for the purpose and kept identifiable no longer than necessary.
Boundary
Any model trained on personal data, especially in the EU and similar regimes.
Symptom or risk
Unused personal data increases breach impact and compliance exposure without improving the model.
Exceptions
Archiving for research or statistics may have longer retention with safeguards; follow legal advice, not this card.
Trade-offs
Short retention limits reproducing old models; keep model artifacts and metadata, and document what was deleted.
Pitfalls
Pseudonymised data treated as anonymous when re-identification is still possible.
Lessons and concepts
Claims and their sources
GDPR Article 5(1)(c) requires data minimisation and Article 5(1)(e) storage limitation.