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My understanding is that the GDPR “right to be forgotten” does not cover backups. There may be some exceptions, but there are practical limits on its reach.
by numbsafari 9y ago
My understanding is that the GDPR “right to be forgotten” does not cover backups. There may be some exceptions, but there are practical limits on its reach.
- theptip 9y agoInteresting, if that's so, can we redefine the underlying Kafka topics as "backups" and achieve compliance by having the stream processors drop "forgotten" records when replaying a topic?
- throwanem 9y agoGood luck selling that one to a judge. Let us know how it goes!
- sulam 9y agoI believe your understanding is incorrect. GDPR certainly includes storage and processing, both of which backups probably trigger. Anyway, think about the spirit of the law, and then think about how that interacts with backups. If someone asks to be deleted from your system, you do so, and then you restore a backup with their data, you have clearly violated the intent.
- tscs37 9y agoKeep a log of deleted users and re-delete upon restore. The GDPR contains exceptions for data storage for which it is infeasible or outside reasonable effort to delete individual records or you have legal compliances to uphold.
- jgeraert 9y agoIsn't the log of deleted users subject to the GDPR then?
- zaarn 9y agoNo since the GDPR exempts things you need for legal compliance, thus a list of users who have asked to be deleted is fine if it's being used to ensure compliance.
- hobofan 9y agoYou can make a log of deleted users without it containing personally identifiable information, by just storing the IDs.
- eledra 9y agoGiven the fact that backup is a must for almost any system, it would be silly for GDPR to not "cover" backup files.