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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

#91

Post by d2wa »

andrei_says_ wrote: post #69
alasdair_ wrote: post #54

Earlier quoted context omitted.

I worked for a company that made games that were used by young children and so covered by COPA. They definitely took a lot of care to delete everything.

How are backups dealt with in this scenario?

The practice developed around the GDPR looks something like this: You keep a separate record of deleted accounts. If you ever need to use or restore from backups, you need to filter the import or other use against that list. You can only do data-integrity checks against the backups and not use it for any purpose, of course. You must notify your local data protection authority if there are any exceptions. Like, if you restored a backup but you can't guarantee that deleted accounts remains deleted.

In other words, you don't need to wipe backups but you can't use them without processes in place to ensure you comply with your customers' rights granted under the GDPR.

Re: Some discouraging anecdotes on how services handle account deletions

#92

Post by DelightOne »

c0balt wrote: post #53
warmwaffles wrote: post #36

Earlier quoted context omitted.

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

Backups usually have limited retention after various data protection agencies. In my current location the recommended time is a few weeks for backups, a few days for logs etc. Those agencies are fully aware that nobody goes around purging data from backups (which may also be hard with airgapped backups etc.) and you might need to wait before being "forgotten".

Are they allowed to restore the account from backup if the user asks for the reopening of the account?

Re: Some discouraging anecdotes on how services handle account deletions

#93

Post by egeozcan »

endominus wrote: post #85
teddyh wrote: post #74

Earlier quoted context omitted.

https://gdpr-info.eu/

Just linking to the root of the documentation itself doesn't help much. The relevant info appears to be Article 17, but even it makes no explicit mention of backups. There is this line, though; "[T]he controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data su…

My previous employer had a "delete on restore" id list, if we ever needed to restore from a backup. My manager said that this should be sufficient for offline backups. They had a lawyer who had said it's OK but I of course don't have the full picture.

It is however a risk, too. The drives are encrypted, without power and not even networked but they can still be stolen together with the encryption key from the same building. But then probably you have bigger problems.

This also forces the systems that test the backups to be also offline, which is a huge hassle.

Re: Some discouraging anecdotes on how services handle account deletions

#94

Post by bluehatbrit »

d2wa wrote: post #91
andrei_says_ wrote: post #69

Earlier quoted context omitted.

How are backups dealt with in this scenario?

The practice developed around the GDPR looks something like this: You keep a separate record of deleted accounts. If you ever need to use or restore from backups, you need to filter the import or other use against that list. You can only do data-integrity checks against the backups and not use it for any purpose, of course. You must notify your local data protection authority if there are any exceptions. Like, if you…

How does this line up with something like a data breach of a backup?

Re: Some discouraging anecdotes on how services handle account deletions

#95

Post by Nextgrid »

ghusbands wrote: post #86
Bombthecat wrote: post #79

Earlier quoted context omitted.

No one really checks Source : talked with people who implemented gdpr deletion at some companies.

So you're suggesting it's okay to ignore the law if the enforcement isn't complete? It's designed to protect people from corporate overreach. Also, given that the EU has been taking increasing action against companies for non-compliance, I wouldn't bet on it remaining unchecked forever. In the intermediate term, I'd bet on there being third-party compliance checks and certificates, with companies that don't use such…

It's not that enforcement is not complete, it's that enforcement is near non-existent. In that case, it makes sense not to spend disproportionate amounts of resources mitigating a very slim risk, especially if your competition is overtaking you because they don't have the burden of compliance.

Re: Some discouraging anecdotes on how services handle account deletions

#96

Post by onion2k »

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.

That was true until the GDPR made it not true.

Re: Some discouraging anecdotes on how services handle account deletions

#97

Post by Nextgrid »

barrkel wrote: post #88
michaelt wrote: post #73

Earlier quoted context omitted.

Given that 99% of GDPR stuff goes unenforced, presumably it's the former. If you understand the GDPR exclusively based on legal precedent, you'd probably conclude the GDPR doesn't exist.

GDPR creates a legal liability. It's less about enforcement and more about litigation risk.

The risk is very minimal or non-existent in the current situation though. Maybe once Google or Facebook is properly fined (with those 4% fines everyone was fear-mongering about) then you'll have to reevaluate, but given how it's gone so far I can't see that happening ever.

Re: Some discouraging anecdotes on how services handle account deletions

#98

Post by spacebanana7 »

Xylakant wrote: post #81
Nextgrid wrote: post #49

Earlier quoted context omitted.

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 al…

A bank would entirely be entitled to keep the info around. All information that must be retained by law (such as receipts, financial transactions etc.) is exempt from the GDPR and you cannot ask for deletion. You can ask that the holder of that information does not use it for purposes other than the ones covered by law, but that’s the full extend of it.

The same principal about foreign key relationships could be applied to messaging apps, restaurant booking services or anything else where a user's relationships with other entities/users would allow them to be identified.

Re: Some discouraging anecdotes on how services handle account deletions

#99

Post by emteycz »

Ansil849 wrote: post #28
mrintellectual wrote: post #27

Earlier quoted context omitted.

Datacenter carbon neutrality and de-biasing ML models are two that I can recall off the top of my head. These are, of course, unrelated to account deletion, but it shows that big tech is at the very minimum aware that social responsibility is becoming a more important part of business.

> de-biasing ML models As exemplified by, for example, Google firing the two heads of their Ethical Artificial Intelligence Team...who had been researching bias? [1] [1] https://www.theverge.com/2021/4/13/22370158/google-ai-ethics...

Are these two the only people who study bias in the world?

Re: Some discouraging anecdotes on how services handle account deletions

#100

Post by jbverschoor »

jbverschoor wrote: post #25

Many companies just as some bodyguards to the login email

... was supposed to say: just add some bogus chars

I requested an account deletion, and because my cookies and session were still active, they simply changed to xxxxxxxxx@xxxx.xxx

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