The process should be the reverse of that. Don't collect data unless you have been through the process of checking that it has a legal basis.
The process should be the reverse of that. Don't collect data unless you have been through the process of checking that it has a legal basis.
I bet the people at Peloton thought that too until they made that treadmill[1]. I know you meant your critique to be absurd, but it turns out creating a child eating machine by accident is entirely possible. I also bet Peloton product development now includes a process to review child-eatingness despite that not being their primary market, just the usual twice burnt reflex.
Accidentally logging the PII can easily happen for a single engineer. I managed to do it on an product that was privacy-focused & the error slipped through review. The odds of such inadvertent errors rise linearly with the number of products and engineers, and the fines are probably superlinear with the size of an offending organization. If your 3-person consultancy chomps on a GDPR baby or 2, no one will ever know about it, but if Google does it, it's going to be news headlines an millions in fines.
Legal basis is ever shifting based on the regional locale. As n+1 requirements pop up, it's only natural to release things like GenChess in the place that requires the least friction, especially when it is not a revenue generating event.