Separate application access from approved use
An employee’s ability to create an account does not mean the tool is suitable for every data category or process. Approval should apply to a defined use case, not to a vendor logo in the abstract.
Ask only for information that changes the decision
A useful request can fit on one page. The requester explains the intended outcome, data, users, verification and current alternative. IT/security checks the provider and configuration; HR, legal or DPO joins where the impact requires it.
- purpose and observable benefit
- data categories and retention
- accounts, access and configuration
- human verification and consequence of error
- owner and reassessment date
Use four explicit outcomes
The outcome can be approved, conditionally approved, more information required or not approved. Conditions must be concrete: excluded data, mandatory verification, required configuration and review deadline.
Preserve the decision and rationale
An approval register prevents contradictory reassessments and helps teams understand why similar-looking uses received different outcomes. A change in vendor terms, purpose or data triggers reassessment.
General educational material. It is not legal advice and does not replace legal, DPO, HR or security review appropriate to your organisation.
