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Last week I was out with an old friend I used to work with many years (& jobs ago), in Edinburgh. Over the last year he has been doing a lot of work around GDPR. Some of it with the adoption authorities, of which he has a particular link, due to a couple of adoptions, made in the late nineties.
We were talking about the many areas where the new GDPR rights cannot be invoked, due to other legal or similar constraint. For example around adoption, adoptee records must be retained for one hundred years legally. Even failed adoptee data, must be held for thirty years.
Clearly these are areas where new ‘Right To Be Forgotten’ etc, will have no effect.
Particularly around ‘Right To Be Forgotten’ / ‘Right to Erasure’, we talked around some scenarios. Where an integrated system is properly in place, (rather than a fragmented hotch-potch of spreadsheets, mixed systems with repeated variants of key data), this should not be such an onerous task.
So what is the basis for the request for erasure of personal data? There are several valid reasons, including withdrawal of consent, data no longer needed to fulfil purpose originally communicated, data subject objects to your processing and you have no overriding legitimate interest basis, or your use was a breach of GDPR.
If an organisation is contacted, can an individual totally be ‘forgotten’? For example, if an organisation is asked to remove all trace of a persons data and there are no legal, or other recognised impediments to that, to follow the full letter of the law, even that ‘request to remove’, should really be erased too.
That is fine, if it was a request from the correct person and details were checked and collaborated before deletion. All is well.
However, if it was not the ‘actual’ person, or a mistake was made and the wrong persons details were erased, how can that be conclusively proved subsequently, without holding audit, containing some details of that erased data, evidence that authenticated the individual? Its an interesting situation, which surely will occur to you or your organisation, before too long.
Could that customer/personal data be ‘taken out of processing’ for a set period, then to be totally deleted, in order to support this scenario? The litmus test, we agreed should always be, is this action ‘reasonable’ and proportionate to any current or potential impact on the data subject.
I would be interested to hear your take on this, as would my GDPR friend up in Scotland OBVs!
Related Post: Control your system configuration well and your KPIs will follow
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Simple Minds – Don’t You Forget About Me.
(c) Tony Smith, Acutance Consulting www.acutanceconsulting.co.uk 07854-655009
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