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IANAL With GDPR right to forget you need to get rid of any identifable subject information. If you can't tell a subject from data then you comply. Encrypted dat
by imhoguy 5y ago
IANAL
With GDPR right to forget you need to get rid of any identifable subject information. If you can't tell a subject from data then you comply. Encrypted data without a key is just a noise.
You are allowed to keep aggregations and hashes of data. These shouldn't allow to identify a subject. E.g. you can keep list of banned emails as MD5s to verify on sign up etc.
- remram 5y agoIn this situation though, any client who still knows the key can access the data, since there is no way to remove data from the database server, or make it unavailable at the server level. Assuming the clients and server are operated by different entities (otherwise the immutability and verifiability are not that interesting), if someone comes to the server operator with a court order and ask that data be removed, it seems like there is nothing they can do.
- setr 5y agoYou can’t do much of anything if you’ve already given away the information in question — the same is true if someone copied the data itself. You have to not give away the key in the first place, at least not to any clients that you don’t own. E.g. following the rule “any problem can be solved with a level of indirection”, external clients get some Auth key A, which they feed to internal client, who internally maps it to some data key B, and decrypts the data and hands it back to the external client. When the data is removed, you delete the mapping from your internal client.