Reply to post: Re: Not my field of expertise

The glorious uncertainty: Backup world is having a GDPR moment


Re: Not my field of expertise

Well this IS my field of expertise, so I'll chime in. :)

Many backup systems have added (or are in the process of adding) features to delete personal data from the backup -- to a certain extent. For example – depending on how your backup is stored – it is technically feasible to delete all spreadsheets, word processing files, or PDFs with a certain person's identifier in them. But asking that same backup product to delete the person's data from within a file or database – while keeping the rest of that file intact – is venturing into extremely dangerous waters. If that's what we're asking, I'll have to agree with the quote in the article form Linus Chang, "deleting data from a backup is a terrible idea because it risks corrupting the backup, breaking referential integrity, breaking applications that were expecting that data to be present, and importantly, breaking any checksums on the data that would prove that a restore was successful."

That leaves the "delete on restore" option. My opinion is that a RTBF journal/database that stores ONLY the unique identifiers (and no other data) – while it sounds on the face a direct defiance of the RTBF – is the best way to ensure the person "stays forgotten" if there is ever a restore from older backups. It's even possible to have the backup system trigger the "make sure these people stay forgotten" process after a restore.

The RTBF article of the GDPR says you can keep data required to defend against a legal claim. In addition to being used for this "make sure they stay forgotten" process, this database I'm proposing can also be used to prove when someone asked to be forgotten, when they were forgotten, etc, in case of a GDPR claim. In addition, the use I'm proposing is also to protect against a legal claim – that you said you forgot somebody that you ended up restoring from backup. Ergo, I think it should be OK to have a RTBG journal/database. I am not a lawyer and am not giving legal advice on GDPR. I'm just spitballing here.

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