EXIN PDPF key terms
EXIN PDPF · Get comfortable with the vocabulary.
- Personal Information (PI)
- Related: Identifiability, Anonymization, Data Subject
Any information relating to an identified or identifiable natural person, recorded electronically or otherwise. Identification can occur directly from the data or indirectly by combining it with other available information.
- Data Subject
- Related: Personal Information (PI), Right to Erasure, Consent
The natural person to whom a piece of personal information relates. Under the law this individual holds rights such as access, correction, and deletion, and organizations owe duties directly to them.
- Personal Information Processor
- Related: Entrusted Processing, Personal Information Protection Impact Assessment, Data Protection Officer
An organization or individual that independently decides why and how personal information is processed. This role carries the core legal obligations, including lawful basis, notice, security, and responding to data subject requests.
- Entrusted Processing
- Related: Personal Information Processor, Processing Agreement, Sub-processor
A relationship where one party handles personal information on behalf of and under the instructions of another. The handler may not use the data for its own purposes and must return or delete it when the engagement ends.
- Sensitive Personal Information
- Related: Separate Consent, Personal Information Protection Impact Assessment, Biometric Data
Categories of data whose misuse can easily harm dignity or personal safety, such as biometric, religious, health, financial account, location tracking, and minors' data. It attracts stricter consent and impact assessment duties.
- Consent
- Related: Separate Consent, Withdrawal of Consent, Informed Notice
A voluntary, specific, informed, and unambiguous expression of will by the data subject permitting processing of their information. It must be obtained freely, without bundling, and can be withdrawn at any time.
- Separate Consent
- Related: Sensitive Personal Information, Consent, Third-Party Sharing
A heightened consent standard requiring a distinct, standalone affirmative action for sensitive data, sharing with third parties, public disclosure, or other high-risk uses. It cannot be buried in general terms and conditions.
- Withdrawal of Consent
- Related: Consent, Right to Erasure, Data Subject Rights
The data subject's right to revoke previously given permission at any time. Withdrawal stops future processing but does not invalidate processing already lawfully carried out, and must be as easy as giving consent.
- Informed Notice
- Related: Privacy Policy, Consent, Transparency
The duty to tell data subjects, before or at collection, the processor's identity, purposes, methods, categories of data, retention period, and how rights can be exercised. Notice must be clear, prominent, and in plain language.
- Privacy Policy
- Related: Informed Notice, Transparency, Accountability
A public document describing how an organization collects, uses, shares, stores, and protects personal information, and how individuals can exercise their rights. It should match actual practices and be easily accessible.
- Lawful Basis
- Related: Consent, Contract Necessity, Legitimate Interest
The legal ground that justifies processing, such as consent, contract necessity, legal obligation, public interest, or vital interests. Every processing activity needs at least one basis, and the chosen basis shapes the applicable duties.
- Contract Necessity
- Related: Lawful Basis, Consent, Purpose Limitation
A lawful basis allowing processing that is indispensable to conclude or perform a contract to which the data subject is a party. It cannot be stretched to cover unrelated marketing or optional features.
- Legitimate Interest
- Related: Lawful Basis, Balancing Test, Purpose Limitation
A lawful basis where processing serves a genuine, specific business or societal need that is not overridden by the individual's rights and expectations. It requires a documented balancing test and appropriate safeguards.
- Purpose Limitation
- Related: Lawful Basis, Data Minimization, Informed Notice
The principle that personal information must be collected for a clear, specific, and legitimate purpose and not further processed in ways incompatible with that original purpose without a new lawful basis.
- Data Minimization
- Related: Purpose Limitation, Storage Limitation, Necessity Test
The principle that only personal information adequate, relevant, and necessary for the stated purpose may be collected and retained. Collecting extra data 'just in case' violates this principle.
- Storage Limitation
- Related: Data Minimization, Retention Period, Anonymization
The rule that personal information should be kept only as long as needed for its purpose or as required by law. Retention periods must be defined, documented, and enforced through deletion or anonymization.
- Retention Period
- Related: Storage Limitation, Right to Erasure, Informed Notice
The defined length of time an organization keeps a category of personal information before deleting or anonymizing it. It should be justified by purpose or legal requirement and stated in the privacy notice.
- Anonymization
- Related: De-identification, Identifiability, Personal Information (PI)
Irreversibly transforming personal information so that it can no longer identify any individual, even when combined with other data. Properly anonymized data falls outside the scope of personal information law.
- De-identification
- Related: Anonymization, Pseudonymization, Identifiability
Reducing the link between data and individuals through masking, pseudonyms, or generalization while retaining re-identification potential. De-identified data generally remains personal information and stays within legal scope.
- Pseudonymization
- Related: De-identification, Anonymization, Technical Safeguards
Replacing direct identifiers with codes so data can still be linked to a person via separately held keys. It reduces exposure but does not anonymize, so the data remains subject to protection obligations.
- Identifiability
- Related: Personal Information (PI), Anonymization, De-identification
The likelihood that a person can be singled out from data, directly or by combining it with other reasonably available information. It determines whether information counts as personal information in a given context.
- Third-Party Sharing
- Related: Separate Consent, Entrusted Processing, Joint Processing
Providing personal information to an external party that will process it for its own purposes. It requires a separate lawful basis, specific notice of the recipient and purpose, and often separate consent.
- Joint Processing
- Related: Third-Party Sharing, Personal Information Processor, Accountability
A situation where two or more organizations jointly determine the purposes and means of processing. They must agree on responsibilities and inform data subjects who to contact to exercise rights.
- Cross-Border Transfer
- Related: Standard Contractual Clauses, Separate Consent, Data Localization
Sending personal information to a recipient outside the jurisdiction. It requires a permitted mechanism such as a security assessment, certification, or standard contractual clauses, plus notice and separate consent where required.
- Data Localization
- Related: Cross-Border Transfer, Security Assessment, Critical Information Infrastructure Operator
A requirement that certain personal information, often for critical infrastructure operators or above volume thresholds, be stored within the country. Cross-border movement of such data needs a security assessment before it can occur.
- Automated Decision-Making
- Related: Profiling, Algorithmic Transparency, Data Subject Rights
Decisions about individuals produced solely by algorithms without human involvement, such as profiling for pricing or credit. It triggers transparency duties and a right to request explanation or refuse decisions with significant impact.
- Profiling
- Related: Automated Decision-Making, Personal Information Protection Impact Assessment, Algorithmic Transparency
Automated use of personal information to evaluate personal aspects such as performance, health, preferences, or behavior. It raises risks of bias and unfair outcomes and requires transparency and, in some cases, impact assessment.
- Personal Information Protection Impact Assessment
- Related: Sensitive Personal Information, Cross-Border Transfer, Risk Assessment
A documented pre-assessment required before high-risk processing, such as handling sensitive data, automated decision-making, entrusting data, or cross-border transfer. It records purpose, necessity, impact on rights, and safeguards, and is retained for at least three years.
- Data Protection Officer
- Related: Accountability, Personal Information Protection Impact Assessment, Compliance Audit
A designated person responsible for overseeing compliance, advising on impact assessments, handling complaints, and liaising with regulators. Certain organizations, including large-scale processors, must appoint one and publish their contact details.
- Data Subject Rights
- Related: Right to Access, Right to Erasure, Withdrawal of Consent
The set of entitlements individuals hold over their data, including access, copy, correction, deletion, withdrawal of consent, explanation of automated decisions, and complaint. Requests must be handled within a defined period.
- Right to Access
- Related: Data Subject Rights, Right to Erasure, Transparency
The data subject's entitlement to know whether their information is being processed and to obtain a copy of it, along with information about purposes, categories, and recipients. Requests should be answered promptly and free of charge.
- Right to Erasure
- Related: Data Subject Rights, Storage Limitation, Withdrawal of Consent
The entitlement to have personal information deleted when the purpose is fulfilled, consent is withdrawn, processing was unlawful, or the contract ends. Exceptions apply where retention is legally required.
- Security Incident
- Related: Breach Notification, Incident Response Plan, Technical Safeguards
Any event involving leakage, loss, theft, or unauthorized access to personal information. The processor must take immediate remedial action and notify regulators and affected individuals where harm is likely.
- Breach Notification
- Related: Security Incident, Incident Response Plan, Accountability
The duty to report a personal information security incident to the supervisory authority and, where individuals' rights are affected, to those individuals. Notification must be timely, factual, and include remediation and mitigation advice.
- Technical Safeguards
- Related: Organizational Measures, Pseudonymization, Security Incident
Controls such as encryption, access control, logging, and pseudonymization applied to protect personal information. They must be appropriate to the risk and reviewed as technology and threats change.
- Organizational Measures
- Related: Technical Safeguards, Compliance Audit, Accountability
Non-technical controls including policies, role assignment, staff training, confidentiality agreements, access approval workflows, and internal audits. They complement technical safeguards and are assessed alongside them.
- Accountability
- Related: Compliance Audit, Personal Information Protection Impact Assessment, Privacy Policy
The principle that an organization must be able to demonstrate compliance, not merely claim it. It requires documented policies, records of processing, impact assessments, training evidence, and audit trails.