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4.3.1 Account of Secure Data Deletion

An accountability policy may include obligations about data retention which include information about the data storage period. According to Obligation 7 in D23.2 [31], "the data controller must make sure that all personal data are deleted (...) after the data collection purpose has been fulfilled". Secure deletion of data is not straightforward and cannot be 100% guaranteed. Existing solutions either remove the link of the data to be deleted or overwrite the content with random data. Some other solutions use cryptography and for example propose encryption of data while storing it and then discarding the decryption key for deletion. It is therefore important to describe how data is deleted. An account of secure data deletion should include the following information:

  • description of the deletion method (unlinking, overwriting, etc.);
  • log traces on delete queries including information on time and location both from primary storage and backup servers;

In addition to this evidence, the account may also include the contact details of the person responsible for this action in case a further problem occurs.