There’s a bunch of cases where a business should not delete data even if requested by a user; the biggie is crime/fraud prevention. However, if that data was l

There’s a bunch of cases where a business should not delete data even if requested by a user; the biggie is crime/fraud prevention. However, if that data was later disclosed in a breach the company would be subject to penalties. The request for removal does count as rescinding consent, so you would no longer be able to do anything that required consent anyhow. Data could be thought of as radioactive so long as it has a unique identifier. If you can aggregate your fraud detection data in some way to remove the pseudonymous/personal identifiers then you should. If you can’t, then your usecase needs to justify the risk of keeping that radioactive material around. Watch out that your aggregates can’t be reverse engineered though. There’s a reasonableness test around how easy it would be to recompile a users profile etc. As technology advances things that were once unreasonable become reasonable think md5). I find it helpful to think of reasonableness being connected to the best 10 people you recently interviewed, or the actions of any competitor in the space. If a prosecutor can point to the competitor and ask why you didn’t do what they did, you need a very good reason to pass reasonableness.