The primary reason this situation should be escalated to the IT steering committee is B. Ethical concerns. This is because using data for a purpose that is outside the original intention may violate the principle of purpose limitation, which states that personal data should be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes1. Using data for a different purpose may also breach the trust and expectations of the individuals who provided the data, and may harm their rights and interests. Therefore, the IT director should consult the IT steering committee, which is a group of senior executives who are responsible for developing and enforcing the organization’s IT priorities and policies2, to determine whether the new use of data is ethical, lawful, and transparent. The IT steering committee should also consider the following aspects before making a decision:

The link between the original purpose and the new/upcoming purpose: How closely related are the two purposes? Is the new purpose compatible with the original purpose or does it contradict it?

The context in which the data was collected: What was the relationship between the organization and the individuals at the time of data collection? What did the individuals consent to or expect from the data processing?

The type and nature of the data: Is the data sensitive, personal, or confidential? Does it reveal any information about the individuals’ identity, preferences, behavior, or opinions?

The possible consequences of the intended further processing: How will the new use of data affect the individuals and the organization? Will it benefit or harm them? Will it create any risks or opportunities?

The existence of appropriate safeguards: What measures are in place to protect and manage the data according to the data protection principles and standards? How can the data quality, security, privacy, and compliance be ensured or improved?

By escalating this situation to the IT steering committee, the IT director can ensure that the ethical implications of using data for another purpose are properly assessed and addressed.