dfk41 Dear Sir,
I am currently a member of coffeeforums.co.uk Username dfk41.
I no longer wish to continue my membership and withdraw my consent for you to use or disclose any of my personal information. I therefore require that you delete my account and all of my details from your servers and confirm when this has been completed.
The sad (from our perspective) thing is that theyâre actually right with their response. We arenât entitled to require them to delete âmy accountâ and/or âall my detailsâ. We can ask for that, but not require it. We can ârequireâ them to delete personal information âŚ. usually. But even that is not absolute. There are caveats about âother legal groundsâ for processing, and âoverriding legitimate groundsâ for continuing to process, and several more.
I find it hard to think of circumstances, in relation to a coffee forum (or almost any other forum, for that matter) account to have such grounds that it would exempt them from the basic right to be forgotten, but even then, it only applies to removing, or anonymising, personal information, not the whole account.
As might be imagined, this is all based on specific laws, and as such is festooned with definitions about which we have to be careful, such as what is and is not considered personal information, and it is even more obscure when it coms to the exact technical interpretation of âanonymisingâ, and âpseudo-anonymisingâ, and so on, at which point itâs a matter of case law as well as statute. Thatâs why I said âusuallyâ. Itâs not an area with many absolutes.
This, of course, is why they should be deleting email addresses, IPâs etc in the profile, and why they would replace a forum name with an anonymised name, like a random number, but while we probably can require them to do that much, we canât require them to do much more. They even covered themelves nicely with the bit about notifying them of exactly what is meant, and where to find it, if we consider there to be other data that would be subject to the right to be forgotten. Something could have, for instance, been manully placed in a given postâs text - tell them what/where, and if it qualifies, no doubt theyâll delete it.
Overall, what they seem to be saying is that theyâll delete what the law requires them to, and nothing more. Thereâs not going to be much anyone can require of them, beyond that.
For anyone wanting to look it up, itâs Article 17 of the UK GDPR, which is the post-Brexit modified UK version of the original EU GDPR.
Oh, one more thing âŚ. my advice, for anyone that cares, is never, EVER put anything on forum that you want to remain private and not be subject to commercial exploitation, and perhaps as important, use a throwaway email address when you sign up for forums, etc. Preferably, a different one for each forum.
It will help keep you anonymised, but if youâre really serious about keeping basic personal info out of commercial use, you need to go a hell of a long way beyond that. Look up, for instance, browser finger-printing. Keeping yourself truly anonymous in this day and age is next to impossible unless you are prepared to take quite extensive and extreme measures to do it. It might (would, IMHO) be justified if youâre living in a dictatorial regime and doing something likely to get you jailed or otherwise disappeared, or I guess something highly criminal, but short of that, itâs going to be a gigantic PITA, and unless youâre extremely careful, probably futile.
There is also a school of thought that says that the best way to remain âhiddenâ, is in plain sight. To be a short and unremarkable weed in a bed of big flowers. If you start going to the extent needed to really disappear from online notice, what youâre really doing is painting a big âstudy meâ target on your back for state actors like intelligence agencies, who are likely to wonder what youâre up to that justify such extremes. So if anybody opts to go that route, youâd better really know what youâre doing, and do it very rigorously, 100% of the time. This privacy thing is a flipping nightmare, but an embedded aspect of todayâs online life. Sadly.
