[gdpr-discuss] Undeleteable data

[TJ]

On 13/04/18 14:54, Gregor Jehle wrote:
> 
> Hi list,
> 
> On 04/13/2018 03:05 PM, Daniel Stone wrote:
>> On 13 April 2018 at 15:00, TJ <0.gdpr-discuss at iam.tj> wrote:
>>> The data subject is giving consent by subscribing or sending to a
>>> mailing list, or creating or adding to a bug report. In this case I'd
>>> suspect ensuring there is an explicit notice that the action is giving
>>> consent would be sufficient (although it's not clear these used require
>>> consent).
>>
>> This is quite a different viewpoint from Moritz's, and was also my
>> reading of it. This is what our current privacy policies and notices
>> express, so people are at least fully aware of the consequences of
>> volunteering information. As it comes from Mailman/Bugzilla, it is not
>> exactly passive: you are voluntarily providing data to be posted for
>> public consumption, and we make people aware of the consequences of
>> doing so when registering/subscribing.
> 
> as I understand the GDPR, a key point is that consent once given is not
> forever. You're able, at any point in time, to decide otherwise and then
> request deletion of your PII.

My point was there is a different requirement for the data required to
provide and operate the service, from the additional voluntary PII a
subscriber might provide.

Also, for a mailing-list, there are two aspects:

1. operating the SMTP relay
2. operating an HTTP archive

For (1) in most cases unsubscribing should remove the data subject's
email address and (optional) (nick)name from the database.

For (2) the challenge is to mask the user's PII without damaging the
thread context. To me that means masking/replacing the To: From: and
reply context like:

>> On 13 April 2018 at 15:00, TJ <0.gdpr-discuss at iam.tj> wrote: