Re:Ask HN: How are you implementing GDPR-compliant soft dele...
by mattmanser on Thursday February 15, 2018 @11:16AM
(#16385164)
This is probably covered by article 17, 3, e:
https://gdpr-info.eu/art-17-gdpr/
You're allowed to ignore deletion rules for the purposes of:
3 Paragraphs 1 and 2 [the rights to be forgotten] shall not apply to the extent that processing is necessary:
(e) for the establishment, exercise or defence of legal claims.
I can see the purpose of "right to be forgotten", but I think in some circumstances it is going to be abused. Any service that "bans" users for fraudulent/abusive activity and stores data about the banned user to prevent them from creating new accounts is going to have a problem. Banned user can just request to be forgotten and then create a new account. Unless there is some exception within GDPR that will support this use case.