The Pitfall of Cataloguing Without Context

In the rush to show progress on privacy, many organisations begin by building data catalogues of personal information. They invest in tools, run workshops, and inventory every system, every database, every field. On the surface, this feels like progress: “we’ve mapped our personal information.” But the truth is, without context, cataloguing is a dead end.

A list of what personal information you hold tells you what you have, but not why you have it or how it is used. Privacy law is grounded in purpose with the very first question always being why was the data collected. A catalogue that simply says “Customer Name – Database X” misses the fundamental point.

Equally important is understanding the journey of personal information through the organisation. Where did it come from? How is it used internally? Who has access? Who is it shared with externally? When is it no longer needed? Recording the existence of personal information without understanding its lifecycle leads to blind spots and risks around personal information being retained too long, shared too widely, or repurposed in ways that stray from its original purpose.

The danger is that catalogues can create a false sense of security. Context is what transforms a catalogue into the foundation of a mature privacy programme. That means layering in purpose and lifecycle stages. It’s the difference between knowing you have a birth date field and knowing you collect it solely to verify age, retain it only during active customer status, and delete it once the relationship ends. Without that context, the risk of non-compliance, and loss of trust, remains hidden.

To succeed, organisations need to map the entire lifecycle of personal information: collection, use, sharing, retention, and disposal. Each item must be linked back to core privacy principles like minimisation, limitation, and transparency. And this mapping cannot be a one-off exercise it has to evolve as the business grows and changes.

A mature privacy programme doesn’t just know what information is held. It understands why it is held, how it is used, and when it should be disposed of. Adding this context is what transforms the exercise of cataloguing into something far more valuable: building trust and demonstrating that personal information is managed responsibly and effectively.