Earlier quoted context omitted.
Yep, we've been through this discussion where I work just a few days ago and one way hashing even with salt is _not_ compliant as you can search for whatever you hashed and get a hit (SSNs, emails etc).
While GP stated soft-deletes aren't allowed, I figured I'd contribute to this thought exercise. What about symmetric encrypting the field(s) and then giving the customer the key, and tell them to print it or store it safely, or else they won't be able to recover? And then don't store the key or write it to disk (remove it from memory)
Ask HN: How are you implementing GDPR-compliant soft deletes?
81–86 of 86 posts
Re: Ask HN: How are you implementing GDPR-compliant soft deletes?
#82Understand what your lawful basis for storing and processing the data is, and that dictates how you need to handle it. Plenty of people throw around large fines and rights to be forgotten and make sweeping statements about "you can't keep X data/we can hash things!/delete all the things". You have a number of potential reasons for storing or processing data. Legal reasons, contractual reasons, consent based reasons - data subjects have different rights depending on the reason you're storing the data (there is a list of these reasons; see below.)
I may be keeping data because I have a contract with a client, and I require the data. An example of this would be an email address stored as a login. My legal basis for storing the information is contractual (I have a contract with my client). Does the data subject (in this case, the user who's email it is) have a right to erasure? No. Can I store the information in my Amazon RDS instance in Virginia? Yes. Provided I've explicitly stated it, and been transparent about how and where I'm storing and processing the data, and my client has agreed. Do I need to secure and look after the data? Yes. Obviously. Do I need to get to get consent from the user? No. That wasn't the legal basis for storing the information.
What about consent based stuff? I may have someone subscribe to my mailing list. I get their consent. Therefore, the legal basis for storing and processing is consent. That consent should be time limited, and I should be transparent about it. I need to give them the means to review, withdraw and act on their consent should they wish to.
What about keeping a record of a person you've deleted because they have requested it? You can store this. Lawful basis is that it's a legal requirement. If you go and use the data for any other purpose, it's not allowed - because that would require their consent.
If you want to understand lawful basis, this is a good overview - https://ico.org.uk/for-organisations/guide-to-the-general-da...
Trying to wade through one half of the GDPR and its requirements without understanding lawful basis leads to confusion, because you'll keep hitting cases that seem completely unreasonable (because they may not be required). Trying to paint the law vague and unreasonable defeats the point - it will become less vague over time. It makes privacy a first class citizen (something we sorely need), and will become more specific as it's tested in the courts, just like any other law in jurisdictions that value legal precedent.
Get to know it and work with it - this is not your mother's EU cookie law.
Re: Ask HN: How are you implementing GDPR-compliant soft deletes?
#83This is how it was explained to me, and the approach we take. YMMV. Understand what your lawful basis for storing and processing the data is, and that dictates how you need to handle it. Plenty of people throw around large fines and rights to be forgotten and make sweeping statements about "you can't keep X data/we can hash things!/delete all the things". You have a number of potential reasons for storing or processi…
Re: Ask HN: How are you implementing GDPR-compliant soft deletes?
#84Earlier quoted context omitted.
My understanding, as someone implementing the GDPR-compliance for my company right now, is that if you could produce the same one-way hash a second time from the same input email address then the hash is still considered PI.
Fair point. I can see the purpose of "right to be forgotten", but I think in some circumstances it is going to be abused. Any service that "bans" users for fraudulent/abusive activity and stores data about the banned user to prevent them from creating new accounts is going to have a problem. Banned user can just request to be forgotten and then create a new account. Unless there is some exception within GDPR that wil…
https://gdpr-info.eu/art-17-gdpr/
You're allowed to ignore deletion rules for the purposes of:
3 Paragraphs 1 and 2 [the rights to be forgotten] shall not apply to the extent that processing is necessary:
(e) for the establishment, exercise or defence of legal claims.
Re: Ask HN: How are you implementing GDPR-compliant soft deletes?
#85Re: Ask HN: How are you implementing GDPR-compliant soft deletes?
#86And secondly, I am going to ask someone I know who is a legal eagle to sign up to this site. She is very clever and knows this stuff backwards. She also has an aspiration to come and work in the US....