Question

A privacy engineer is supporting a project that migrates customer records from an on-premises order-management system into a new SaaS platform. During the extract-transform-load (ETL) process, the team discovers that several free-text 'notes' fields in the legacy system contain embedded personal data (e.g., health remarks, alternate contact details) that were never part of the documented data model. What should the privacy engineer recommend FIRST before the load step proceeds?

Accepted Answer

Assess the embedded personal data against the migration's documented purpose and lawful basis, then transform or exclude fields that fall outside the approved scope

Answer

Load all fields as-is to preserve data integrity, and schedule a post-migration data quality review to clean up the notes fields later

Answer

Encrypt the entire notes column during transit and at rest so the undocumented personal data is protected in the new platform

Answer

Pseudonymize the notes fields by tokenizing all free-text values before loading them into the SaaS platform