I think that was the initial concept of what "Full Disk Access" was supposed to be, but I've run into needing to give some of my own apps full disk access for very innocuous reasons. Recently, I wanted to build a little app to give me a Time Machine on/off switch by calling "tmutil enable/disable". A single on/off command with no need to access any of my data, but its use was gated behind needing Full Disk Access. Hopefully if Apple is rethinking Full Disk Access permissions they will rethink better ways to provide these sort of permissions.