We had very long discussions with our lawyers to make our email analytics solution [1] compliant to the very strict german privacy laws and GDPR. Ip addresses a

We had very long discussions with our lawyers to make our email analytics solution [1] compliant to the very strict german privacy laws and GDPR. Ip addresses are personally identifiable information because someone is able to find the real person an ip address belongs to - your ISP. That you have no possibility to get them to hand you over this information and it wouldn‘t be legal makes no difference. It‘s a big joke. The solution is to anonymize the last ip adresses octet. You can (within some boundaries) work with the full ip address. In your case technically you would be violationg these rules because you are saving person identifiable information without your customer aknowledging this before. And you even transmit these information to other services. The joke is, this is how the internet works and this rule is practically not enforcable for everyone (we solved it for our solution). The least you could do to be a little bit compliant is to state in your rules that you are logging the customer‘s ip address and tell them every service you transmit this information to for transparency reasons. For the backup case with AWS RDS it‘s again not practical. The law has not been made by texhnicans. The simple answer is everyone is violating the law. In my opinion it will take 2-3 years and all these very openly stated rules will be clarified and in the end will be more logical. Until this day you could store an information which information should be deleted in another database and if AWS needs to restore your main database you use the seconds database information to delete the information again. You can then state its technically not feasible to delete some information from backups that you did your best. But then you should not store backups for 10 years, they should have much smaller timespans. [1] https://mailspice.com/ https://mailspice.com/