GDPR: What? I don’t have to delete data.

Where is that data?

Auto generate data inventory

Ref Model (data inventory) in Elements.cloud

So now what?

To delete or not

  • Right to Subject Access Request (Article 15); a customer can ask for a report of everywhere you hold their data
  • Right to Rectification (Article 16); a customer can ask you to update data that is inaccurate
  • Right to Erasure (Article17); “right to be forgotten”, so a customer can request that you delete all data you hold on them. There are provisions to allow you to hold their data for certain valid reasons, such as the need to hold it by law, but it also allows for anonymization
  • Right to Restriction of Processes (Article 18); a customer can request that you do not ‘process’ their data because it is incorrect, there is no reason for you to hold it, or they have raised a request to object
  • Right to Receive Personal Data (Article 20); a customer can request that their data be provided to them in “structured, commonly used and machine-readable format” so that they can pass it to another company
  • Right to Object (Article 21); a customer can object to your holding their data because you have no reason to and that it be deleted

Deletion and archiving at end of production system retention period

Source: OwnBackup 2018 Webinar Survey “GDPR Right to be Forgotten: Compliance for your backups”

Production, archives, backups and sandboxes

The deletion process

The final word

Resources

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Founder & CEO Elements.cloud: OrgConfessions.com, Salesforce customer & evangelist since 2002 : Author : Speaker bit.ly/IGshowreel

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Ian Gotts @iangotts

Ian Gotts @iangotts

Founder & CEO Elements.cloud: OrgConfessions.com, Salesforce customer & evangelist since 2002 : Author : Speaker bit.ly/IGshowreel

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