What is our data erasure policy to support the "Right to be forgotten"? (Art. 17 GDPR):
In line with European data regulations (GDPR) commits inSided to removal of all customer data, (including all personal data) of consumers upon termination or expiration of the service contract. The data removal policy and procedures tap into all relevant sectors of the inSided Platform across the architecture and application layers. The following sectors are manipulated to make sure all customer data is safely and thoroughly removed.
Sectors:
- Git repository, builds and backups
- Static File Delivery Storage (AWS Cloudfront and S3)
- Databases on all development instances and release stages, including local environments (DTAP)
- Offsite backups related to Disaster Recovery Plan (DCP)
- SSL domain certificates
- DNS records (AWS Route 53)
- Load balancing instances and logs (AWS Elastic Load Balancing (ELB))
- API key/secrets for all environments
- Configuration settings
- Event store
- Technical analysis and consultancy exports
- Search indexes
User anonymization process:
Steps taken to anonymize a community user:- Community manager or admin can login to inSided backend application "Control";
- Within user management, he or she can find and select the user;
- By choosing and verifying wanting to anonymize the user, the following steps are automatically executed:
- Username is anonymized
- IP addresses known for user events are anonymized
- Email address is anonymized
- SSO identifier is anonymized
- Profile field values are deleted
- Private messages are deleted
- The steps described in point #3 are performed on the production databases, and will be effective in all hot and cold backups (i.e. off-site) within 7 days after execution;
- User is now fully anonymized, meaning no personal data is available anymore, nor in the system nor in any backup - the user record can no longer be retrieved.
- Erased users will come up as ‘Anonymous’ on the platform, their content will be left intact to avoid damage to the community - but the attached user record is now Anonymized.