Data Erasure Request Procedure (PRV-PROC-002)
1. Purpose
The purpose of this procedure is to describe the systematic process for handling data erasure requests (right to be forgotten) from users under GDPR, CCPA, and other privacy regulations, ensuring complete and verifiable deletion of personal data while maintaining system integrity and legal compliance.
2. Scope
This procedure applies to all user requests for personal data deletion including account closure, specific data deletion, and right to erasure requests. It covers all data types and systems containing user personal data across all geographic regions and service components.
3. Overview
This procedure ensures comprehensive data deletion through automated systems and manual verification, balancing user privacy rights with legal retention requirements and platform operational needs while providing transparent communication throughout the deletion process.
4. Procedure
| Step | Who | What |
|---|---|---|
| 1 | User | Submit data erasure request through platform privacy settings, support interface, or email with clear specification of deletion scope and requirements. |
| 2 | Privacy System | Automatically acknowledge erasure request within 24 hours, verify user identity, and initiate legal basis assessment for data retention requirements. |
| 3 | Privacy Analyst | Verify user identity through multi-factor authentication and assess deletion request scope including account data, content, and associated metadata. |
| 4 | Legal Review | Evaluate legal basis for data retention including ongoing legal holds, regulatory requirements, financial obligations, and legitimate business interests. |
| 5 | Technical Assessment | Identify all systems containing user data including primary databases, backups, logs, analytics systems, and third-party services requiring deletion coordination. |
| 6 | User Communication | Notify user of deletion timeline, scope limitations due to legal requirements, and implications including loss of account access and content. |
| 7 | Data Deletion | Execute systematic deletion across all identified systems using automated deletion tools with real-time monitoring and verification of deletion completion. |
| 8 | Backup Processing | Schedule deletion from backup systems during next backup cycle refresh, implementing deletion markers for immediate backup exclusion. |
| 9 | Third-Party Coordination | Notify third-party processors and service providers to execute deletion of shared personal data according to data processing agreements. |
| 10 | Verification Testing | Conduct automated and manual verification to confirm complete data deletion including database queries, system searches, and backup verification. |
| 11 | Anonymization Review | Review remaining anonymized or aggregated data to ensure no personal identifiers remain and data cannot be re-identified. |
| 12 | Completion Notification | Provide user with deletion confirmation including completion date, scope of deletion, and any retained data with legal justification. |
| 13 | Audit Documentation | Document complete deletion process including systems affected, verification results, legal basis for any retained data, and compliance attestation. |
| 14 | Quality Assurance | Conduct random post-deletion audits to verify deletion effectiveness and identify any system gaps requiring process improvement. |
5. Standards Compliance
| Procedure Step(s) | Standard/Framework | Control Reference |
|---|---|---|
| 1-3 | GDPR | Art. 17 |
| 1-3 | PCI DSS v4.0 | Req. 3.2.1 |
| 4 | GDPR | Art. 17.3 |
| 4 | PCI DSS v4.0 | Req. 7.1.1 |
| 6-7 | CCPA | § 1798.105 |
| 6-7 | PCI DSS v4.0 | Req. 9.8.1 |
| 9 | GDPR | Art. 19 |
| 9 | PCI DSS v4.0 | Req. 4.1 |
| 10-11 | GDPR | Art. 17.1 |
| 10-11 | PCI DSS v4.0 | Req. 9.8.2 |
| 12 | CCPA | § 1798.130 |
| 12 | PCI DSS v4.0 | Req. 12.1 |
6. Artifact(s)
A comprehensive data erasure record containing deletion request details, legal assessment, systems inventory, deletion execution logs, verification results, third-party notifications, user communications, and compliance certification stored with appropriate retention periods for audit purposes.
7. Definitions
Right to Erasure: GDPR provision allowing individuals to request deletion of their personal data under specific circumstances.
Data Deletion: Technical process of permanently removing personal data from all systems, databases, and backups.
Legal Basis for Retention: Legitimate legal, regulatory, or business justification for retaining personal data despite deletion request.
Deletion Markers: Technical indicators preventing deleted data from being included in new backups while existing backups undergo refresh cycles.
Data Processing Agreement: Contract requiring third-party processors to delete personal data upon instruction from the data controller.
Anonymization: Process of removing personal identifiers to ensure data cannot be attributed to specific individuals.
Verification Testing: Technical validation confirming complete data deletion across all systems and storage locations.
8. Responsibilities
| Role | Responsibility |
|---|---|
| [Privacy Department/Team Name] | Manage deletion request workflow, coordinate cross-functional execution, verify completeness, and ensure regulatory compliance and user communication. |
| Technical Team | Execute automated deletion procedures, verify technical deletion across all systems, and maintain deletion tools and monitoring capabilities. |
| [Legal Department/Team Name] | Assess legal basis for data retention, evaluate deletion limitations, and ensure compliance with regulatory and contractual obligations. |
| Database Administrators | Execute database-level deletions, manage backup deletion schedules, and verify data removal from all storage systems and archives. |
| Third-Party Management | Coordinate with external processors for deletion execution, verify third-party compliance, and maintain deletion confirmation documentation. |
| Quality Assurance | Conduct deletion verification testing, audit deletion completeness, and identify opportunities for process improvement and automation enhancement. |