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Soft deletion probably isn't worth it

brandur.org

451–460 of 514 posts

Re: Soft deletion probably isn't worth it

#451
post #360
post #334

Earlier quoted context omitted.

>You can’t delete IP as this is not covered by GDPR, but you sure can ask them to delete your identification data from their records as GDPR also works for employees not just customers. You can ask , but the right to have data erased is not an absolute right. In fact there's an enumerated list of the circumstances in which the data must be deleted but data controllers are otherwise under no specific obligation to del…

It’s an absolute right, and one of the main points of GDPR, unless there are another law[0] stating that you can keep it, for a specific reason. Like financial transactions. When that law expires then GDPR kicks in. The company doesn’t own your data, you do. [0] https://gdpr-info.eu/art-17-gdpr/

>It’s an absolute right, and one of the main points of GDPR, unless there are another law[0] stating that you can keep it, for a specific reason.

It can't be "an absolute right... unless", it's either absolute or it's not.

And if you read Article 14 the first paragraph says that "The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies" (emphasis mine) and then lists six grounds. Further to that, paragraph 3 dis-applies paragraph 1 for more reasons than "another law states you can keep it".

>The company doesn’t own your data, you do.

Data controllers do own the data (insofar as one can "own" data), but data subjects have rights over the processing of those data that limit what the controllers may do with them.

Re: Soft deletion probably isn't worth it

#452
post #407

Earlier quoted context omitted.

Sure, but that time period is usually limited to 30 days, with an additional 30 day extension allowed if you contact the person and tell them you need more time. You can’t just declare that it take years to delete data, GDPR sets reasonable limits on how long a company can delay true deletion.

The GDPR says it's 30 days with a 2 month extension. This allows for having safe soft deletion and backup retention policies without running afoul of it.

The GDPR says data should be deleted "without undue delay", it doesn't give a hard deadline.

Re: Soft deletion probably isn't worth it

#453

Earlier quoted context omitted.

Yeah. Basically anything that an employee can mess up, should be reversible IMO. But actions such as deleting an account should have the option of "YES, DELETE IT PERMANENTLY, THIS CAN'T BE UNDONE"

You probably want to put the account on hold for a period where it can be undone. And then clean it up after.

Not always possible in a legal way. For example, GDPR compliance.

Re: Soft deletion probably isn't worth it

#454

Earlier quoted context omitted.

I don't know why you're ragging on Node.js users or even PHP for that matter as both ecosystems have this stuff covered too. Also you're comparing language/runtime with an actual framework and then dogging those users... If you want to compare Rails with Node/PHP then I'd suggest comparing with things like Laravel (PHP), Adonis (Node) and you'll find everything you can do in Rails is done in Node/PHP too.

What percentage of production Node.js systems use Adonis? It's probably vanishingly low. Laravel is nice, and it's been gaining a lot of adoption in new applications, but the GP said "90s PHP" for a reason. Modern Node JS backends are often littered with hand rolled SQL queries, poor MVC separation, and lots of shoddy, half baked model layers—often without using any library whatsoever. Which is a real shame, because…

How is hand rolled SQL queries something bad?

Re: Soft deletion probably isn't worth it

#455
post #440
post #253

Earlier quoted context omitted.

I would guess that there are quite a few limits to that... A user has a long history of participating on your forum and other users have quoted their messages far and wide. Collectively all of the messages posted on your forums (with or without timestamps) reveal a few PII about the user. Do you have to delete those? The user filed a bug report about a functionality not working, do you have to delete the text of the…

user_id is PII if the identity of a user can be narrowed down sufficiently. For example, if you created a social media app and later left the company, it could still be determined that if you had an account it likely has one of the lowest user ID values if those were assigned sequentially. So even if your name was removed from it and none of your posts provided any identifying information about you, the user ID could…

The question is not whether "spooky deanonymization as a distance" is possible; the question is how much you should proactively do to avoid this.

As an extreme example, if user A takes a screenshot if their own user setting page on a image sharing site, then sends it to user B that uploads it to the same site. Who is responsible for this piece of data? does share-a-pic.web need to scan all images for the username of a user that is deleting an account?

This is a convoluted example where the answer is obviously no, but it shows that a purely principled answer might be unsuitable.

Especially since non PII data you own mixed with non PII data someone else owns can become PII and you do not know what data others have.

(you could also replace the user ID in all locations with a new tagged UUID to preserve referential integrity in the DB, but there not much more than 2^32 humans in total, it s very hard not to be deanonymizable)

Re: Soft deletion probably isn't worth it

#456
post #276

Earlier quoted context omitted.

It's illegal but companies don't necessarily care to avoid soft deletes regardless. I think companies wait to get sued so they can try to argue in court why their soft deletions are reasonable and why it's too technically difficult for them to do hard deletes. To be honest, in the age of modern overprovisioned storage drives that remap blocks frequently, I'm not really sure you can implement genuine "hard" deletes wi…

GDPR fines are structured to make it extremely risky/expensive to take the “ask for forgiveness not permission” approach you’re suggesting. I think for this reason, the fine is designed to scale with the size of the offending company’s revenue, not so much with the actual damages suffered by anyone. Take a look at some of these fines, tens of millions of euros cause the UI for your cookie consent dialog is poorly des…

> GDPR fines are structured to make it extremely risky/expensive to take the “ask for forgiveness not permission” approach you’re suggesting.

Expensive, maybe, but not risky.

If you're rolling the dice on a GPDR fine, the expected value of vague compliance is still largely positive, while the expected value of actual compliance is still slightly negative.

The expected value of the fine needs to be a larger negative than the expected value of vague compliance.

You don't even need to raise the fine value (which is a percentage/scale of revenue), you just need to make the probability of paying it approach 1.

In fact, with a higher probability of paying the fine, you could even lower the actual fine and still have it have a larger negative expected value than vague compliance.

Re: Soft deletion probably isn't worth it

#457

Earlier quoted context omitted.

Guess we’ll find out when a leaks happen, and companies start getting fines. GDPR does differentiate between structured data (I believe it uses the term “identifiable records” or similar), and huge heap of unstructured data where an individuals data can’t be quickly retrieved as it’s own atomic unit. With much stricter requirements for anything structured. So for data on a HDD that could be recovered, but is an unstr…

What does GDPR say about obscuring data? Instead of hard-deleting a structured record for Bob Smith, can you leave the record intact and scrub it of identifying data so that I don't e.g. break all of the records for orders that Bob Smith made?

> Instead of hard-deleting a structured record for Bob Smith, can you leave the record intact and scrub it of identifying data so that I don't e.g. break all of the records for orders that Bob Smith made?

The various laws (GPDR, and similar ones in my jurisdiction) abuse the hell out of vague descriptions like "personal identifying data".

For example, scrubbing a customer record of all names, phone numbers, contact info, etc and leaving only the ID in the record still makes it possible to personally identify the person by:

1. Looking through the orders records to build up a profile depending on what they order,

2. Then using the delivery records from the courier company to get an address,

3. Then using existing public information to repopulate all the fields in the customer record.

In any given business, no matter how big or small, simply removing all references to a customers personal information will still leave the customer personally identifiable. This process can even be automated.

Re: Soft deletion probably isn't worth it

#458
post #276

Earlier quoted context omitted.

It's illegal but companies don't necessarily care to avoid soft deletes regardless. I think companies wait to get sued so they can try to argue in court why their soft deletions are reasonable and why it's too technically difficult for them to do hard deletes. To be honest, in the age of modern overprovisioned storage drives that remap blocks frequently, I'm not really sure you can implement genuine "hard" deletes wi…

GDPR fines are structured to make it extremely risky/expensive to take the “ask for forgiveness not permission” approach you’re suggesting. I think for this reason, the fine is designed to scale with the size of the offending company’s revenue, not so much with the actual damages suffered by anyone. Take a look at some of these fines, tens of millions of euros cause the UI for your cookie consent dialog is poorly des…

> YouTube sets cookies on our devices to track our online activity for marketing purposes

This is not the purpose of cookies. The purpose of cookies is to store state on the browser side. Does GDPR interpret all possibilities of "cookies" as the storage and communication of privacy-violating data? Because that would be extremely unfortunate

Re: Soft deletion probably isn't worth it

#459

Earlier quoted context omitted.

The author uses the "no one ever undeleted anything" as the primary justification. I think this is the part they miss. I've never undeleted a user either, but there have been many times I've gone back to look at something. Either a complaint finally gets around to me as to why the user wanted their account deleted (e.g. feature not working) and it helps to figure out why. Or they're returning and want things set up l…

I think this is the part they miss. I've never undeleted a user either, but there have been many times I've gone back to look at something. Yeah. As far as a user-facing "Undelete" button existing or being used... that's very rare in my experience. What's much more common is a user accidentally deletes some data. They deny they made an error. The developers are blamed. You then have to go on a wild goose chase figuri…

+1 to investigating user error. It also happens that you have bugs, and it's hard to spot the bugs if you don't have a quick way of filtering out all the cases of user error.

> Yeah. As far as a user-facing "Undelete" button existing or being used... that's very rare in my experience.

This is pretty common in my experience, but often with slightly different terminology. I've seen "delete"/"undelete" but also "move to trash"/"restore from trash" or "mark for deletion"/"unmark for deletion" and even "archive"/"restore from archive" where deleted/marked/archived objects were excluded from normal business processes and were hidden in the UI unless the user went to a special page where they could search, view, and restore.

I've also seen chat functionality where users had the ability to delete messages but admin users had the ability to view the full history of a chat, including deleted messages. (The software was used by businesses to communicate with their customers, who were also businesses, so supervisors being able to read deleted chat messages was appropriate.)

In my experience soft delete is basically free if you do it from the start. I've never regretted soft delete but have always regretted the lack of it. However, it's easier if you also have a data retention policy from the start so you're forced to create automated cleanup processes and maintain them as you go along.

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