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My understanding is that you have to be able to remove PII like usernames, email addresses, and such. The actual message sent to other recipients is not covered
by sethammons 8y ago
My understanding is that you have to be able to remove PII like usernames, email addresses, and such. The actual message sent to other recipients is not covered, but the envelope information would be. For envelope look up (sender, recipient), have those as hashes that are in a look up table. If the sender sends you a GDPR request, delete them from your hash look up and display "user deleted" as the "from" user on the message.
Obviously, run this through your lawyer as I am not one.
- lmkg 8y agoThe message contents may contain PII as well. For example, you could send your phone number or mailing address to someone else.
- jdietrich 8y agoThe GDPR is not concerned with "personally identifying information", but "personal data". It defines the latter very broadly, viz: ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; Even if they're completely stripped of metadata, instant messages are highly likely to contain information that could indirectly identify the sender or recipient.