4 ms·
You have to show a pretty strong need to keep PII after a user has expressly withdrawn their permission for you to carry on processing it. No, it's not uncommo
by oliwarner 4y ago
You have to show a pretty strong need to keep PII after a user has expressly withdrawn their permission for you to carry on processing it.
No, it's not uncommon to "tombstone" data, but when you do that, you should remove data you have no rights to any more. Order numbers, accounting, payments that sort of stuff is all fair game (for limited time), but the point here is it appears they're not deleting anything, they're just moving it to be inaccessible to the user.
They keep the data. And that's a) scummy and b) illegal in several jurisdictions.
- otterley 4y agoIf the records no longer contain PII, then they've arguably satisfied their duties under the law, haven't they? Has a court held otherwise?
- edmundsauto 4y agoI think replacing the userid with an ID that isn’t reversible but keeps all the foreign key constraints is acceptable.