Define the evidence

A publication does not need an unlimited visitor dossier to learn whether its articles are useful. Begin with the decisions the team will make: which topics to improve, which channels bring relevant readers and which enquiries deserve follow-up. Map each decision to the minimum data needed. Separate aggregate editorial reporting from identifiable sales records, and define who needs access to each. More data can create more maintenance and privacy obligations without improving the decision.

Make it operational

Write a measurement plan covering purpose, fields, access, retention and the applicable consent or other requirements for the chosen tools and markets. Have the appropriate privacy owner review it. Avoid putting sensitive information into analytics event names or URL parameters. Provide a route for handling privacy requests through the organisation’s established process. Revisit the plan when adding a new tracking tool, because a technical integration should not silently expand the information collected beyond the purpose originally agreed.

Imagine this

Hypothetical example

A journal tracks article views and enquiry submissions in aggregate, while its sales team keeps only the information needed to respond to a request. It does not send free-text enquiry messages into general analytics. The reports remain useful without duplicating sensitive conversation details across systems.

Make it practical.

Use this checklist as you read. Checks are not stored.

References & further reading

Further reading: ICO data minimisation ↗

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