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I think your approach with UUIDs is practically equivalent to my suggestion involving hashing: you replace something that is the actual personal data with an ir
by Silhouette 9y ago
I think your approach with UUIDs is practically equivalent to my suggestion involving hashing: you replace something that is the actual personal data with an irreversible proxy.
My concern remains the same either way. It's not that such measures can't technically be implemented, it's that the effort required to do so in practice is disproportionate, particularly for smaller organisations using limited personal data for legitimate purposes where there is little risk to privacy from otherwise properly handled data not being fully deleted on demand.
For example, instead of a small transport business buying a standard backup service and using backup and restore tools that just save all their important data to a secure, reliable location in case of disaster, it appears that they might now have to implement data crunching logic customised to their specific circumstances, despite possibly having no knowledge about how databases or programming work at all.
I fail to see how such a requirement would be constructive in terms of safeguarding anyone's privacy in a meaningful way, but I also fail to see how it isn't required according to the letter of the GDPR.