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by thayne 633 days ago
It's more than just not spying on people. You have to be able to prove you don't spy on people. And any vendors or contractors you use also don't spy on people, and respond to requests from anyone about all the data you have on them. And delete all of the data you have for anyone who cancels their account. Sure in some cases, that isn't a huge burden, like if you have a website that doesn't handle any customer data. But if you have a non-trivial app where you need to handle a lot of customer data for your app to work, it is a significant burden. And deleting someone's data as soon as they cancel can be really bad if someone accidentally cancels, so you probably want some kind of delayed deletion.
1 comments

You don't have to delete as soon as they cancel; you can store it in an encrypted backup which you remove after 90 days (and throw away the key). There are a lot of 'for a reasonable period' things; meaning, you cannot store PII (including IPs) forever and you cannot store it at all in case you do not need it in the first place for your app to function (example; SaaS asking for my home address which they don't ship anything).
> you can store it in an encrypted backup which you remove after 90 days (and throw away the key)

Sure. But that is much easier said than done. Especially if your previous strategy was to just keep everything, because storage is cheap, development cost is expensive, and then the data will still be there if the customer decides to return in a few years.

And in many (most?) cases it's not like you just have a single file with all the user's data, that data is spread around in many different database tables , and possibly even multiple databases. The development work to figure out how to clean everything up, without accidentally deleting anything wrong or leaving anything out can be a considerable amount of effort.

It's also not always black and white who data belongs to. If I upload an image onto a document that was shared with me, should that image be deleted if I cancel my account? What about something I posted publicly on a social media platform? Or posted privately in a group chat or DM? Does it make a difference if the content of an image or text I wrote included PII? Hopefully you have a lawyer that understands the nuances involved.

I see this and I feel I must ask: why would you EVER engineer ANY application under the idiotic assumption that none of your users will ever want to remove the data that they had stored in it?! Absolutely baffling. Of course, if a business is that short-sighted and careless, it will struggle to implement GDPR.
It might be more nefarious when companies do that, but on the other hand, Hanlon's razor.