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Comment by daveFNbuck | Hacker News Reader

You don't necessarily have to delete stuff from cold storage right away. You just need to have a process to remove deleted PII when you retrieve/rewrite your backups.

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This might be a bit of a weird question, but how do you remember which information needs to be deleted when you're at the point where you need to use backups?

You would keep a list of unique identifiers (opaque) that were deleted and filter data out prior to rewriting/restoring it. It’s cumbersome but not impossible.

So basically more work.

So I need to keep a list of people to delete from my backups when I restore them? Is keeping that list even GDPR compliant?

The gist seems, if you are sticking your fingers into your ears hard enough and shouting loud enough, it should count, maybe, in at least most European nations.

But remember, strictest interpretation wins.

So you then need to make sure that dataset is at least as resilient as your cold backups. That's not exactly a trivial problem in most cases.

You need backups of which information needs to be deleted. Or you can just store PII separately from the rest of your data so most of your backups don't need to be modified.

How long are you keeping backups in cold storage for - usually you'd want maybe 6 months there, but no more, otherwise it's just going to grow unbounded and become a financial burden.

That's certainly a valid point, but it still doesn't solve the problem of having to remember to delete something in the event of data loss.

As far as I can tell to comply with a deletion request with absolute certainty requires infallible storage (which would remove the need for backups) or modifying backups (which contradicts the concept of a backup). Maybe you can claim 'force majeure' at some point, but perfect compliance seems impossible.

It's impossible to have absolute certainty about almost anything. That's not what the law requires.

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