4 ms·

INAL, but... you might want to revisit that code. article 17, right to erasure is about erasure of personal data, not about making non-indentifiable. of course

INAL, but... you might want to revisit that code. article 17, right to erasure is about erasure of personal data, not about making non-indentifiable. of course they dont define erase or delete :-) (edit: typo)

Aperocky 5y ago
well to me the transaction is the same as deleting a record and populating a NULL record. I don't see why the law should care in any way about a company populating NULL records.
- FigmentEngine 5y ago
  "NULL out all identifying information" is anonymization, not deleting the information.
  - duncans 5y ago
    I wrote zeroes to my hard drive. Would you consider the data on my hard drive merely anonymized, or is it deleted?
    - ranguna 5y ago
      It's deleted because all connections (and meta data) has been erased. In a database, if you null all fields but keep the entries and their inter table relationship intact, you still have identifiable data up to a certain point. Imagine you have data of specific people and you only have one person per country, having a user and country relationship, if you null a single data of a specific user, you'll still be able to find the user just by analysing to which country that user was connected + some external information. This is the classical problem of deriving personal data from statistical reports and why data anonymisatiom is so complex.
- izacus 5y ago
  > I don't see why the law should care in any way about a company populating NULL records. It cares if the existence of this record still leaks private data. This is why talking about generic "records" here is pretty wrong - actual data is not interchangeable "records" where you can just slap on a generic cargo cult policy and think you're done. Different use-cases require different data handling. Although, I do agree, for most CRUD cases it's enough to NULL out rows.
Tarq0n 5y ago
If you erase all identifying parts it stops meeting the definition of personal data. That should be sufficient.
deleted 5y ago
[deleted]

Aperocky 5y ago

well to me the transaction is the same as deleting a record and populating a NULL record. I don't see why the law should care in any way about a company populating NULL records.

FigmentEngine 5y ago
"NULL out all identifying information" is anonymization, not deleting the information.
- duncans 5y ago
  I wrote zeroes to my hard drive. Would you consider the data on my hard drive merely anonymized, or is it deleted?
  - ranguna 5y ago
    It's deleted because all connections (and meta data) has been erased. In a database, if you null all fields but keep the entries and their inter table relationship intact, you still have identifiable data up to a certain point. Imagine you have data of specific people and you only have one person per country, having a user and country relationship, if you null a single data of a specific user, you'll still be able to find the user just by analysing to which country that user was connected + some external information. This is the classical problem of deriving personal data from statistical reports and why data anonymisatiom is so complex.
izacus 5y ago
> I don't see why the law should care in any way about a company populating NULL records. It cares if the existence of this record still leaks private data. This is why talking about generic "records" here is pretty wrong - actual data is not interchangeable "records" where you can just slap on a generic cargo cult policy and think you're done. Different use-cases require different data handling. Although, I do agree, for most CRUD cases it's enough to NULL out rows.

Tarq0n 5y ago

If you erase all identifying parts it stops meeting the definition of personal data. That should be sufficient.

deleted 5y ago

[deleted]