[BNM] GDPR shenanigans

Andrew Smith andy at robotlovesyou.com
Thu Aug 5 14:57:57 BST 2021


The last company I worked at, they took the approach of taking data out of
processing, but making it retrievable in case of some future legal action.
I was told that that is the legal advice they had received, but that is
probably a question for a lawyer.

Best

Andrew

On Thu, 5 Aug 2021 at 15:52, Ian B <ibrierley at gmail.com> wrote:

> Being reversible sounds weird, and against it to me, but I'm no expert. I
> feel like that's maybe a misunderstanding....I'm not quite sure how you got
> to that point from the document linked ?
>
> I take it more that if a person contests the information is incorrect, or
> for example you need some historic information for billing verification or
> whatever, you keep that information, but there should be no further
> processing of that information ?
>
> Otherwise I could ask Company X to delete my personal information including
> that £10k I owe them :D, but I'm probably misunderstanding something a bit.
>
> Just an aside, I think it's also ok to keep some parts of personal
> information, i.e keeping their email address on a blacklist or something,
> so as never to contact them again if requested (that could be hashed though
> I guess).
>
>
>
>
> On Thu, Aug 5, 2021 at 2:37 PM Simon Early <simon.early at gmail.com> wrote:
>
> > listertians,
> > Can anyone help me out on this question?
> >
> > GDPR - when you delete a record, must it be immutable and
> non-reversible? -
> > deleted is deleted
> > OR!
> > If requested by a court (for example) should you be able to restore the
> > data you have obfuscated? so, kinda not-quite-deleted
> >
> > Isnt the whole point of GDPR that it's permanently erased?
> >
> > confused!
> >
> > * section 47(2) of the Data Protection Act 2018...*
> >
> >
> >
> https://www.legislation.gov.uk/ukpga/2018/12/section/47#:~:text=47Right%20to%20erasure%20or%20restriction%20of%20processing&text=(2)Where%20the%20controller%20would,personal%20data)%20restrict%20its%20processing
> > .
> >
> > so we currently have 3 options for clients:
> >
> > 1. retain and send me a copy
> > 2. delete and send me a copy
> > 3. delete
> >
> > am I now to put in a 4th option of
> >
> > 4. delete it but make it reversible if requested by a court ie make it
> > "un-processable"
> >
> > help!
> >
> > cheers,
> > Simon
> > ---
> > Simon Early
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