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Start with the purpose, not the fields a scraper can find
Write down the intended use before collection, then identify the minimum information needed to achieve it. The European Commission describes personal data as limited to what is adequate, relevant and necessary for the purpose, and says organisations should collect and process only data needed to fulfil that purpose. The controller must assess how much is needed: there is no universal contact-field checklist. European Commission: What is personal data?
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For example, if a task requires routing a business inquiry, a person’s name and a relevant business contact channel may be sufficient. A home address, personal social profile, or unrelated biographical detail does not become necessary simply because it is publicly visible or easy to extract. Whether any particular field is justified depends on the actual use.
Decide what to keep before the scraper runs
Turn the purpose into explicit inclusion and exclusion rules. A short collection plan makes it easier to configure filters and to spot overcollection before it becomes part of a larger dataset.
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- Use case: State what the contact data will be used for, narrowly enough to guide collection.
- Required fields: List the fields needed for that use; avoid collecting optional fields “just in case.”
- Identifiability: Consider whether a field identifies someone directly or could do so when combined with other information.
- Excluded categories: Name the data categories that do not serve the purpose and should be filtered or avoided.
- Retention and deletion: Set a retention period and a deletion trigger for data that is no longer needed.
- Accuracy: Decide how you will check that records are current and reliable enough for the intended use.
These are practical planning questions, not a regulator-issued universal template. The right fields and retention period depend on the purpose and circumstances.
Filter unnecessary information at collection
Where the source and extraction method permit it, configure the scraper to collect only the categories that meet your criteria. CNIL recommends defining specific criteria in advance, filtering unnecessary categories where possible, and excluding sites that structurally contain categories that are not needed for the purpose. CNIL: Scraping websites—guide to collecting data lawfully
If effective filtering is not practical, reconsider whether that source is appropriate at all. CNIL gives financial transaction data and geolocation as examples of categories that may be unnecessary in a particular use case. It also points to sites used mainly by minors as sources to consider excluding when they structurally contain data categories that are not needed. These are context-dependent examples, not a universal list of prohibited sources.
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Delete accidental overcollection promptly
Filters can fail, pages can change, and a source may contain more than expected. When irrelevant information is collected despite your criteria, CNIL says to “ensure that any irrelevant data that may have been collected despite these criteria is deleted immediately after collection or as soon as it is identified as such.” CNIL guidance on website scraping
Make that instruction operational: review extracted fields against the collection plan, remove nonessential fields from records, and delete irrelevant data as soon as it is identified. If the same unwanted category repeatedly appears, adjust the extraction rules or stop using that source rather than allowing the excess to accumulate.
Set retention and deletion separately
Minimising what you collect does not answer how long you may keep what remains. The European Commission identifies storage limitation as a GDPR principle: personal data should not be kept longer than necessary for its purpose. It also lists the storage period, or the criteria used to determine it, among the information provided to individuals whose data is processed. European Commission: GDPR principles
Choose a retention period based on the actual use and define what event triggers deletion—for example, completion of the task for which the records were gathered. The cited guidance does not supply a single duration that suits every dataset. For data obtained indirectly, the Commission says information generally must be provided no later than one month after obtaining the data, or at the first communication with the individual or first disclosure to another recipient, whichever comes first. Applicability and exceptions require case-specific review. European Commission: Information for individuals
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Public access does not settle whether scraping is lawful
The EDPB says GDPR applies where web scraping processes personal data, including through collection, storage, organisation or retrieval. Its guidance highlights the need to consider lawful basis, purpose limitation, transparency and special-category data. Finding contact details on a publicly accessible page does not, by itself, answer whether a particular collection and subsequent use comply with the GDPR. EDPB: Respect individuals’ rights
This article addresses EU data-protection principles, not every legal issue raised by scraping. It does not determine the lawful basis for a specific operation or resolve national rules outside the EU, marketing-contact requirements, or website terms. Those questions depend on the activity and jurisdiction and need separate assessment.
Check the workflow before relying on the dataset
Use these questions to review a proposed workflow. They are decision prompts based on the cited authorities’ concerns, not an official scoring system.
- Is the purpose specific, and are the necessary fields defined before collection?
- Can the scraper filter out unnecessary categories at the source?
- Could the sources contain sensitive information or data about vulnerable people that the task does not need?
- Is there a process to remove accidental overcollection promptly?
- Are the retention period and deletion trigger defined?
- Will accuracy and source reliability be checked for the intended use?
- Have transparency obligations and the lawful basis been assessed for this operation?
In web scraping for generative-AI use, the EDPB recommends reliable sources, timestamping and validation. That advice is specific to the AI-related context addressed by the guidance; it is not a universal technical mandate for every scraper. EDPB: Guidelines 1/2024 on processing personal data
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