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It’s pretty easy: just don’t restore their data. Most businesses with personal data also have invoices. Since you don’t have to destroy those, simply note thei

by geocar 9y ago

It’s pretty easy: just don’t restore their data. Most businesses with personal data also have invoices. Since you don’t have to destroy those, simply note their request there. Other kinds of personal data like marketing leads and medical data should be much easier to see how to forget.

hamandcheese 9y ago
That isn’t easy from a technical perspective. The whole point of a backup is to restore to a state from a previous point in time... now they want future state (the “right to be forgotten” request) to modify how a backup should be restored?
- geocar 9y ago
  No. The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. If someone sends you something in the post telling you to delete their data, it should not be difficult to simply keep that record available when you need to restore an unrelated machines backup, unless you have incompetent IT. This is part of the reason many GDPR consultants suggest applying an IT standard like ISO so that it’s clear you already know what backups are for and how to use it. A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible.
  - hamandcheese 9y ago
    > The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. And to then restore to a point in time before the software or hardware bugs occurred, no? > A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible. Um what? There are ton of good reasons to stick to a single DB, it’s not unreasonable at all. The main one being that it massively simplifies ensuring data integrity compared to a distributed system. Also it’s just easier for a small team to manage.
    - geocar 9y ago
      A single point of failure isn't a good way to protect people's personal data that you have, but even small teams are unlikely to have a single golden source of data. Data tends to flow from one system into another. For example: If someone sends you an email asking to be deleted, why would you store that email in the DB and nowhere else? Your team would read the email then update the database. After a crash, if you then restored a backup, why wouldn't you be able to review your last days email (since the last backup) for any updates? Of course you would. Even small teams could.
  - Silhouette 9y ago
    If someone sends you something in the post telling you to delete their data, it should not be difficult to simply keep that record available when you need to restore an unrelated machines backup, unless you have incompetent IT. "Who's IT?" -- Small and micro-businesses across Europe This is part of the reason many GDPR consultants suggest applying an IT standard like ISO so that it’s clear you already know what backups are for and how to use it. "We can't even afford a GDPR consultant. And who's IT?" -- Small and micro-businesses across Europe A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible. Again, this is simply detached from the reality of many, many small and microbusinesses, community organisations, non-profits, etc. It's absurd to think that every organisation that has reasonable need to handle personal data has a dedicated IT team, the people and budget to drop a few thousand on professional advice, the budget to buy extra equipment that isn't otherwise needed, etc. It's also absurd to think that without those things, an organisation can't take reasonable precautions to protect that data or prevent its exploitation for illegitimate purposes. Unfortunately the GDPR (as often happens with EU legislation) makes little allowance for any of this and thus imposes absurdly disproportionate overheads on smaller organisations.
    - geocar 9y ago
      A flower shop owner who runs his own website off a laptop in his shop unattended but plugged into his DSL using Microsoft Personal web Server and Windows 98, who records customer data in that form without explaining to his customers that he's a fucking idiot deserves what he gets. It's a shame perhaps that the European courts probably won't bother with him. But the photographer that hosts her website and help forms on wix[1] isn't going to have any problems. The local restaurant using viewtouch PoS and a facebook page isn't going to have any problems[2]. [1]: https://support.wix.com/en/article/general-data-protection-regulation-gdpr https://support.wix.com/en/article/general-data-protection-r... [2]: https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr https://www.facebook.com/business/news/facebooks-commitment-... Very few real people will have any problems, because the GDPR is fundamentally about tradeoffs: If you have a lot of personal data, you need to protect it and inform the subject what you do with it. If you can't afford to protect it and think that the subject wouldn't want you doing what you're doing with their data, then you probably shouldn't have that personal data.
  - eadmund 9y ago
    > The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. And process bugs/defects. And human error. Human error such as, for example, 'delete all of Mr. Smith's records.'
    - geocar 9y ago
      Sure. And if that same human error can also delete all the email and postal mail that Mr. Smith sent to your company, then your IT team is criminally irresponsible.

by geocar 9y ago

hamandcheese 9y ago

That isn’t easy from a technical perspective. The whole point of a backup is to restore to a state from a previous point in time... now they want future state (the “right to be forgotten” request) to modify how a backup should be restored?

geocar 9y ago
No. The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. If someone sends you something in the post telling you to delete their data, it should not be difficult to simply keep that record available when you need to restore an unrelated machines backup, unless you have incompetent IT. This is part of the reason many GDPR consultants suggest applying an IT standard like ISO so that it’s clear you already know what backups are for and how to use it. A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible.
- hamandcheese 9y ago
  > The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. And to then restore to a point in time before the software or hardware bugs occurred, no? > A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible. Um what? There are ton of good reasons to stick to a single DB, it’s not unreasonable at all. The main one being that it massively simplifies ensuring data integrity compared to a distributed system. Also it’s just easier for a small team to manage.
  - geocar 9y ago
    A single point of failure isn't a good way to protect people's personal data that you have, but even small teams are unlikely to have a single golden source of data. Data tends to flow from one system into another. For example: If someone sends you an email asking to be deleted, why would you store that email in the DB and nowhere else? Your team would read the email then update the database. After a crash, if you then restored a backup, why wouldn't you be able to review your last days email (since the last backup) for any updates? Of course you would. Even small teams could.
- Silhouette 9y ago
  If someone sends you something in the post telling you to delete their data, it should not be difficult to simply keep that record available when you need to restore an unrelated machines backup, unless you have incompetent IT. "Who's IT?" -- Small and micro-businesses across Europe This is part of the reason many GDPR consultants suggest applying an IT standard like ISO so that it’s clear you already know what backups are for and how to use it. "We can't even afford a GDPR consultant. And who's IT?" -- Small and micro-businesses across Europe A single machine/database with all your business data on it mixed with personal data and the only record of requests from subjects is criminally irresponsible. Again, this is simply detached from the reality of many, many small and microbusinesses, community organisations, non-profits, etc. It's absurd to think that every organisation that has reasonable need to handle personal data has a dedicated IT team, the people and budget to drop a few thousand on professional advice, the budget to buy extra equipment that isn't otherwise needed, etc. It's also absurd to think that without those things, an organisation can't take reasonable precautions to protect that data or prevent its exploitation for illegitimate purposes. Unfortunately the GDPR (as often happens with EU legislation) makes little allowance for any of this and thus imposes absurdly disproportionate overheads on smaller organisations.
  - geocar 9y ago
    A flower shop owner who runs his own website off a laptop in his shop unattended but plugged into his DSL using Microsoft Personal web Server and Windows 98, who records customer data in that form without explaining to his customers that he's a fucking idiot deserves what he gets. It's a shame perhaps that the European courts probably won't bother with him. But the photographer that hosts her website and help forms on wix[1] isn't going to have any problems. The local restaurant using viewtouch PoS and a facebook page isn't going to have any problems[2]. [1]: https://support.wix.com/en/article/general-data-protection-regulation-gdpr https://support.wix.com/en/article/general-data-protection-r... [2]: https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr https://www.facebook.com/business/news/facebooks-commitment-... Very few real people will have any problems, because the GDPR is fundamentally about tradeoffs: If you have a lot of personal data, you need to protect it and inform the subject what you do with it. If you can't afford to protect it and think that the subject wouldn't want you doing what you're doing with their data, then you probably shouldn't have that personal data.
- eadmund 9y ago
  > The whole point of backups is to protect against hardware failures and unforeseen software bugs/defects. And process bugs/defects. And human error. Human error such as, for example, 'delete all of Mr. Smith's records.'
  - geocar 9y ago
    Sure. And if that same human error can also delete all the email and postal mail that Mr. Smith sent to your company, then your IT team is criminally irresponsible.