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> it helps for documentation purpose should the dispute arise over some issue in future. If you are required to hold on to the data for legal purposes such as
by Ezku 9y ago
> it helps for documentation purpose should the dispute arise over some issue in future.
If you are required to hold on to the data for legal purposes such as dispute settlement, there is no issue. The customer can request you delete such data but you have no obligation to do so. Issues arise when holding on to the data is no longer "necessary". At that point soft deletion is not enough and you must be able to remove personal data regarding that customer from your systems. Source: IP lawyer I talked with last week on this.
From what I can tell, one good way of going about this in case you really do not want to throw away data – such as when you're doing event journaling – would be to have all personal data encrypted. When the data reaches its expiration point or is requested for deletion, throw away the decryption key and all you're left with is is the metadata which you are allowed to hold on to for purposes of running your business.
EDIT: This concept is called 'cryptographic deletion'. Here's one whitepaper on the subject. http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.397.857 http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.397....
- andriesvh 9y agoAre you sure about throwing away encryption keys is sufficient to be GDPR complient? Does this comes from IP lawyer as well?