I don't think your statement holds true in practice. Collecting data that you then don't do anything with, in theory or even in practice, is also something that GDPR penalizes, since there's no need for you to collect it if you claim you don't do anything with it.
Not doing something with the data is also a function, just like Nulls are a value, so yes you are right that collecting the data and not doing anything with it could be viewed negatively when up before data commissioners. Its interesting watching how the IT industry views GDPR and the advice given out by various law firms. You see unlike maths which is pure, language is vague and open to interpretation, the trick is convincing the decision maker ie data commissioner or judge that your interpretation is the correct one and not just an incorrect herd mentality sweeping the IT industry, which you see in the comments posted here and elsewhere.