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What about deleting data in backups for an EU resident who submitted a request for data deletion? If a company is using mysqldump or equivalent it seems difficult to just drop certain records from those .sql files.



Have a reasonable retention policy on these backups. Backups are a "legitimate business interest" and you don't need to purge "right to be forgotten" requests from your backups if you stick to a reasonable and publicly-documented retention policy. This is advice that I've received from counsel. However, I am not a lawyer, and this in no way should be taken as legal advice.


If you ever had to restore from backup, I hope you kept track of what content now needs to be "re-forgotten"


We received similar advice from our legal counsel, but got stuck on this implementation detail.


Difficult yes, impossible not.


Of course. For us, it came down to cost. EU customers make up <1% of our revenue. Implementing this non trivial feature didn’t make sense for us financially. So, we decided to drop all EU customers entirely.




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