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I think that depends on what you mean by compliance. Some regulations require you to irreversibly destroy data when they prescribe the destruction of that data.

That can mean as much as "you have to encrypt everything with a separate key, so that you can destroy the key for the given (say, personally identifiable) dataset making its retrieval irrecoverable"

I'm not saying that's the particular compliance reason they had here, or that the analysis you're giving is wrong, either. There is an interpretation where either of these ideas could be the correct one.



This is why regulations specify that data must be destroyed within a time period, typically 90 days. It gives enough time for backups to rotate out.

If this weren’t a concern, regulations would demand immediate deletion of data.


"permanently delete" strongly suggests to me that it was the "medical and financial data" kind of compliance. If data can be restored, it's not permanently deleted. But this was a statement from the CEO, so words can have arbitrary meaning :)


"permanently delete" does not mean the same thing as "immediately delete". deleting from the live database is the first step of a permanent deletion, as long as the data exists somewhere the deletion process is still in-progress.

there's a whole lot of people in here who are way too quick to assume that just because one part of a permanent deletion process was inadvertently triggered and then caught while they still had backups, their whole permanent deletion process is a lie.


https://ico.org.uk/for-organisations/guide-to-data-protectio...

You seem to be right-ish, while the gdpr in certain circumstances allows you to keep backups of data that should have been deleted it seems like they are trying to discourage it in the future.

> ...It is, however, important to note that where data put beyond use is still held it might need to be provided in response to a court order. Therefore data controllers should work towards technical solutions to prevent deletion problems recurring in the future.


A better way to do this sort of thing is not an actual "delete", but a "cryptographic delete". The data should be encrypted, and you just delete the key. The data is then unrecoverable everywhere, including backups. Of course you probably don't want to just nuke the key, but disable it for some period of time, and then nuke it.


i don't see how that really changes anything - your keys should be backed up just as much as, if not more than your data. and any process for deleting the encryption keys should allow for restoring from backups for some period of time just the same as your process for deleting data should allow restoring from backups for some period of time. either way, permanently rendering data as unrecoverable takes time.


As an example, if you are using Amazon's KMS for key management and you destroy a key it gives you 7 days to undo before permanently destroying the key. Or you can disable they key and destroy it later as your retention policy permits. Surely they have some kind of key backup, but KMS users have no access to those backups.




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