Where does it all end?
Dave's comparison of big and small businesses set me thinking. It's not necessarily the big organisation that doesn't realise what it's doing with PII. If anything they may have better resources to carry out a formal analysis and pick up on such things whilst a more informally managed SMB might not.
But this line of thinking extends down to the purely personal holding of PII. What about personal friends and family phone and address books? Your Christmas card list? SWMBO's ladies group (definitely NOT part of the WI!)? Does sending Christmas cards escape by being counted as a transacton?
Is a line drawn anywhere and if so where? What about the email list of a group of friends who meet in each others' houses to play bridge? Or a larger group that hires the village hall? Or the village hall management committee?