Navigating GDPR in OSINT Investigations
A practitioner's guide to balancing OSINT investigative necessities with GDPR requirements, covering legitimate interest, data minimization, and practical compliance.
The General Data Protection Regulation (GDPR) fundamentally changed how personal data is handled, and OSINT investigations are not exempt simply because the data is public.
Legitimate Interest as a Legal Basis
Most private sector OSINT relies on 'Legitimate Interest' (Article 6(1)(f)). This requires balancing the investigative objective against the privacy rights of the individual.
You must document this balancing act via a Legitimate Interests Assessment (LIA) before widespread data collection begins.
Data Minimization
Do not collect more than you need. If you are investigating a subject's corporate affiliations, downloading their entire family's social media history violates the principle of data minimization.
The Right to be Forgotten vs. Investigative Necessity
Subjects may request data deletion. However, exceptions exist for legal claims or prevention of financial crime, provided the retention is strictly necessary and proportionate.
Privacy-First Investigations
Aletheia helps teams enforce data retention policies and track lawful bases for data collection directly within the investigation workspace.