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by jahav
1026 days ago
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Spoken like a person who never even touched it even on a small project. No cookies... so no language preferences. That is a profile cookie. Right to erasure. What about invoices and orders? When can it be anonymous and when is it old enough to anonymize. Do I get away with replacing personal data random data? Do I replace references to real people with 'anonymous person'? Will my sql constraints still work? When I restore data from backup and someone has been anonymized in the meantime, what mechanism will be used to anonymize the user after restore? Right to data portability. How much of the database and in what format? |
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You can find guidance or good advice online for all of your questions.
> No cookies... so no language preferences. That is a profile cookie.
This is one of the examples of “strictly necessary” cookies, which do not require consent. See section 3.6 here: https://ec.europa.eu/justice/article-29/documentation/opinio...
> Right to erasure. What about invoices and orders? When can it be anonymous and when is it old enough to anonymize.
Invoices should typically fall under the “legal obligation” legal basis (article 6(1)c). See for how long the law requires you to keep them. In my country, it's 10 years.
>Do I get away with replacing personal data random data?
Yes, see WP216.
>Do I replace references to real people with 'anonymous person'? Will my sql constraints still work?
How do you do when someone deletes their account?
>When I restore data from backup and someone has been anonymized in the meantime, what mechanism will be used to anonymize the user after restore?
It's up to you to decide.
>Right to data portability. How much of the database and in what format?
The same as for a DSAR. As for the format, it's up to you to decide, provided it is a commonly used format.