Nonsense. If you're made aware you're storing PII, fine. That's different. If it's a field designed for something else, and you have no knowledge it's being use

Nonsense. If you're made aware you're storing PII, fine. That's different. If it's a field designed for something else, and you have no knowledge it's being used to store PII? You're not going to get a penalty for that. This isn't American law, where everything seems to be decided based on technicalities and the exact wording of the law. These decisions are made by reasonable human beings who review the facts of the situation and come to a judgement.