Yes. That’s the point. I’m building the capability to comply with the deletion requirements. But prior to that requirement the systems _didn’t_ have any usage of the personal info.

If you didn't have any use for that data, why was it being stored in the first place? If it continues to not be necessary for your business, why don't you stop recording it instead of building an index to remove them after the fact?

Usually it’s a case where a data provider gives you data that is necessary for a business but _also_ includes data you don’t want or need.

Some process will ingest and index the valuable data and throw the original file into non-indexed storage in case it needs to be re-run.

Ideally you filter that data at ingest time but even that is building a capability that feels against the intent.

But let’s say you didn’t even know to build the filter. Now you need to go in and scan all those files to remove the personal data. A capability that requires you to read data you hadn’t prior.

So, you are just building a huge pool of personally-identifiable data that you are holding onto for no commercial or business reason or benefit to the user?

You’re literally the reason the law was passed. Don’t do that. Like what happens when you get hacked or leave an Amazon bucket public and someone sells all your customers’ PII on the dark web?

A lot of HN’ers “”struggle”” with the concept that the law isn’t “confusing” or “bad” it’s that they themselves are taking actions that are socially harmful and laws have been passed to target this behavior. But it’s difficult to make a man understand something when his paycheck depends on not understanding it.

The axiom has been for businesses to hoover up as much data as possible, and that’s explicitly the mindset the EU wants you to stop. Being asked to at least catalog what you’re hoovering up is a tiny tiny ask, let alone the immense risks you’re running with other people’s identifiable data. Don’t create these targets for people to hack in the first place, especially when they self-admittedly serve no useful purpose even to your marketing.

You’re literally the guy getting mad the government is making him clean up his superfund site. Moving the drums is riskier than just letting them sit there forever… up until they inevitably rust out.

https://en.wikipedia.org/wiki/Valley_of_the_Drums

“I ain’t hurtin’ nobody, it’s a free country!”

I agree that in an ideal case the data wouldn’t be collected or stored.

My concern is once it has, is it better to build a capability that can specifically be used to identify personal data to remove it or to let it lie.

I’m glad you have moral certainty on that. It’s certainly never been that clear to me.

If you are able to build something to identify PII from your dataset, anyone is. So if you "let it lie", once you (inevitably) leak the data, someone else can just build that same thing and get the PII.