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Some discouraging anecdotes on how services handle account deletions

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Re: Some discouraging anecdotes on how services handle account deletions

#41

Post by karaterobot »

Nextgrid wrote: post #35
organsnyder wrote: post #30

Earlier quoted context omitted.

That's illegal under the GDPR and many other privacy laws and is subject to heavy fines if caught. I work in privacy at a large tech company, and we take this stuff extremely seriously.

The heavy fines everyone is fear-no getting about are a running joke now. It took 4 years and a non-profit making lots of noise for a brazen, obvious and malicious GDPR breach to be investigated despite it being plastered on every single website out there (I’m talking about non-compliant consent popups). To date, the accumulated fine amount over the 4 years and all fined companies is around a billion. Now lookup the…

Yep. And you can extend that to all security compliance, not just GDPR. The biggest driver for compliance is being able to give solid answers on VSA questionnaires, not actually being secure. Certainly not fear of getting fined or failing an audit. The number of companies who get caught is so small, and the amount they get dinged for is so minuscule that it's not even a concern for them once they figure out how it works.

Re: Some discouraging anecdotes on how services handle account deletions

#43

Post by ehnto »

I guess it can get complicated, but most of the software I've written I gracefully handle missing user relationships so that it's possible to delete the user. I wouldn't be surprised if a lot of these circumstances are just because the software can't handle a missing user relationship, nothing nefarious. Stupidity before malice and all that.

Re: Some discouraging anecdotes on how services handle account deletions

#44

Post by hobs »

warmwaffles wrote: post #36
organsnyder wrote: post #31

Earlier quoted context omitted.

As long as all PII is purged in this process (tricky to guarantee with software like Confluence that is entirely dedicated to hosting user-generated data), that could be compliant.

I wonder if they also go through all of their backups and purge the PII. I would be willing to bet, they don't.

Not required by the GDPR... so they will not.

Re: Some discouraging anecdotes on how services handle account deletions

#45

Post by EdwardDiego »

Nextgrid wrote: post #34
organsnyder wrote: post #31

Earlier quoted context omitted.

As long as all PII is purged in this process (tricky to guarantee with software like Confluence that is entirely dedicated to hosting user-generated data), that could be compliant.

Technically the foreign key relationships could themselves be considered identifying data.

How do you mean?

Re: Some discouraging anecdotes on how services handle account deletions

#46

Post by EdwardDiego »

itvision wrote: post #6

I've worked for several companies and let me tell you the truth: * accounts are never deleted, period * At most there's a column in the table which specifies whether the account is alive or not. That's it.

You can create a special deleted user account, and that claims ownership of FK relations that would break things. But then a lot of relational datastores aimed at Big Data (tm, rights reserved, patent pending) don't do super well at updates.

Re: Some discouraging anecdotes on how services handle account deletions

#47

Post by tfigment »

Nextgrid wrote: post #38
ChrisMarshallNY wrote: post #22

The app I'm writing does this very well. That's because Apple requires it. They won't approve my app, unless there's a "full-fat delete" option. If a user of the app deletes, it completely nukes their entire account, down to the last byte.

Does Apple have any way to verify it’s actually a full delete, and do they do so? There is public evidence that a lot of apps lie on their privacy labels and they seem to get away with it.

I assume Apple verifies everything on the phone is removed so no cookies left behind for next app or reinstall.

Re: Some discouraging anecdotes on how services handle account deletions

#48

Post by Nextgrid »

tfigment wrote: post #47
Nextgrid wrote: post #38

Earlier quoted context omitted.

Does Apple have any way to verify it’s actually a full delete, and do they do so? There is public evidence that a lot of apps lie on their privacy labels and they seem to get away with it.

I assume Apple verifies everything on the phone is removed so no cookies left behind for next app or reinstall.

I thought we were talking about server-side account delete?

Re: Some discouraging anecdotes on how services handle account deletions

#49

Post by Nextgrid »

EdwardDiego wrote: post #45
Nextgrid wrote: post #34

Earlier quoted context omitted.

Technically the foreign key relationships could themselves be considered identifying data.

How do you mean?

Let’s imagine you’re a modern bank and associate card transactions with the merchant.

Even if you sanitize/delete the account holder record, you can’t delete the transactions themselves (as it would screw up your accounting) nor the merchant association.

Now let’s say you have a very particular customer that always goes to a very specific restaurant at pretty much the same time every day consistently.

That pattern alone is enough to single out that particular person (and deanonymize them by correlating with other records such as cell phone location data, etc).

Re: Some discouraging anecdotes on how services handle account deletions

#50

Post by bjornsteffanson »

Nextgrid wrote: post #38
ChrisMarshallNY wrote: post #22

The app I'm writing does this very well. That's because Apple requires it. They won't approve my app, unless there's a "full-fat delete" option. If a user of the app deletes, it completely nukes their entire account, down to the last byte.

Does Apple have any way to verify it’s actually a full delete, and do they do so? There is public evidence that a lot of apps lie on their privacy labels and they seem to get away with it.

> Does Apple have any way to verify it’s actually a full delete, and do they do so?

The guidelines do state that it should be a full delete. In my experience, Apple has never checked or asked to verify if a user account was fully deleted on apps I've worked on, which involve PHI. It's been a part of HIPAA compliance for our apps since the beginning (and we do actually fat delete, FWIW). It's a relatively new requirement from Apple's end, though. The deadline was actually extended from January 31st 2022 to now June 30th 2022. Enforcement or stringency on Apple's part could change around then, but I don't see Apple having the resources or willpower to do much of an increase here.

Full guidelines are here: https://developer.apple.com/news/?id=i71db0mv

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