🔷 SERIES: 30 DAILY PERSONAL DATA PROTECTION COMPLIANCE SCENARIOS IN BUSINESS - #20: COLLECTING ID CARDS FOR CUSTOMER VERIFICATION: WHEN IS IT JUSTIFIED – AND WHEN SHOULD YOU STOP?
- loanlelawlinkvn
- 37 minutes ago
- 2 min read
In many business models, requesting customers to provide ID cards or images of identity documents is often seen as a standard verification step. However, from a personal data protection perspective, this is an activity that requires more careful consideration than collecting basic contact information. Having a customer transaction does not automatically justify collecting copies of identity documents.
The first question to ask is whether the verification purpose genuinely requires this type of data. If the objective can be achieved through less intrusive means, businesses should consider alternative approaches instead of defaulting to ID collection. The more sensitive identification data is collected beyond what is necessary, the greater the risks related to storage, access, copying, and misuse in subsequent stages.
A practical tip for customer onboarding teams:
Businesses should conduct an ID document necessity review before introducing ID collection requirements into forms, apps, or transaction processes.
Mini-checklist:
• Clearly define the business purpose for collecting identity documents;
• Assess whether less intrusive verification methods are available;
• Limit ID collection to transaction types that genuinely require it;
• Strictly control the storage of photos, scans, and internal copies;
• Define who can access, download, and when the data must be deleted or access restricted.
In personal data governance, the key question is not “can we collect this data,” but “is it truly necessary to collect it to this extent?”
Legal reference:
Law on Personal Data Protection No. 91/2025/QH15 and its implementing framework, particularly provisions on data processing principles, necessity, purpose limitation, and data security.
CTA:
A practical checklist is available at the link below:
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Article: Prepared by LLVN.
Image: LLVN
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