Danish DPA Publishes Guide On Data Minimization And Right Of Erasure

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Forget me yes.

The Danish data protection authority has published a practical guide on data minimization and the right of erasure under GDPR:

  • If you use “soft delete,” a link is deleted but not the personal information in the underlying database, this is not a real deletion.
  • Based on the purposes of the processing, and subject to legal retention requirements, the data controller must determine and document the deletion deadline for each processing.
  • Data controllers must develop deletion procedures for systems where personal data is processed and must implement a follow-up procedure to ensure deletion.
  • For accountability, data controllers may keep a log of requests received under the right to be forgotten. They should set reasonable deletion deadlines for the log.
  • Personal data must be deleted from backups if technically possible. If not, data controller must ensure that the personal data deleted from the system in operation is also removed if a backup is restored.

Read the guide.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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