According to GDPR, any person has 'Right to Erasure (Recital)' and have his/hers sensitive information deleted. Does that mean that an organization can keep all non-sensitive data for a user?

For an example, if there is a Database record:

         Phone|  Option|     Actived|  Deactivated|  ...
(555)-123-4567|       A|  2017-04-12|   2018-01-10|  ...

If all sensitive information is deleted and information is reduced, such as:

         Phone|  Option|     Actived|  Deactivated|  ...
(XXX)-XXX-XXXX|       A|        2017|         2018|  ...

This process of hiding users data is considered anonymization and as such should not be applicable. On the other hand, this approach will ensure that information about users who had option A activated last year will be kept without storing the users personal information.

However, by matching multiple sources, someone COULD potentially still find out what this number was.

Does this mean that reasonable effort was put into securing the users sensitive data or does 'Right to Erasure' mean just that, delete everything about that user? That seems like it would seriously harm a lot of organization analytic.

1 Answer 1


You did read the exceptions?

(3) Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defence of legal claims.

  • 1
    I have 0 experience in law whatsoever, but couldn't one argue that erasure would seriously impair any statistic? This statistic isn't something this organization needs to function, but it is essential to see the organizations growth and make decisions about its future. Maybe I didn't structure my question very well, but I meant that this erasure occurs long after there is any need to process the subjects data so point e) about legal claims is not valid.
    – alturkovic
    Commented Feb 14, 2018 at 7:43
  • @aturkovic that doesn't refer only to legal claims brought by the specific individual whose info was stored, so it may not necessarily mean that point E) is inapplicable.
    – A.fm.
    Commented Feb 14, 2018 at 18:31
  • 1
    @A.fm. Particularly if there have been commercial transactions between the organisation and the individual- evidence of that may need to be kept indefinitely.
    – Dale M
    Commented Feb 14, 2018 at 19:05

You must log in to answer this question.

Not the answer you're looking for? Browse other questions tagged .