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Right to Be Forgotten / Data Erasure Requests

  • 1.  Right to Be Forgotten / Data Erasure Requests

    Posted 08-04-2021 09:16 AM
    Good morning!

    I'm curious about an apparent circular issue regarding the practical implications of Right to Be Forgotten / Data Erasure Requests: If we remove all information on a constituent we would also have no record of the constituent's desire to be forgotten Were we to re-acquire their contact information as part of a new acquisition effort we would not know that they do not want to be contacted. To honor the request seems impractical. I've read about the loopholes in GDPR and I know most US laws are not up to par, but I don't know at which point we would be able to say we cannot completely honor the request if the constituent is not a donor. At the least, we owe the constituent a response, so I'd be interested in the direction other institutions have chosen and the responses you provide to such requests.

    Thanks in advance.
    Gregory


    ------------------------------
    Gregory Amarante
    Director of Philanthropy CRM
    The Trust for Public Land
    gregory.amarante@tpl.org
    ------------------------------


  • 2.  RE: Right to Be Forgotten / Data Erasure Requests

    Posted 08-04-2021 11:49 AM
    Gregory, it is permitted to keep sufficient data for suppression purposes. A clarification was issued about this:

    ICO Direct Marketing Guidance
    Version: 2.2 19th May 2016
    "Organisations should maintain a 'suppression list' of people who have opted out or otherwise told that
    organisation directly that they do not want to receive marketing. Note that individuals may ask an organisation to remove or delete their details from a database or marketing list.
    However, in most cases organisations should instead follow the marketing industry practice of suppressing their
    details. Rather than deleting an individual's details entirely, suppression involves retaining just enough information to
    ensure that their preferences are respected in the future" (Para 190-192).


    Thank you,
    Isaac Shalev
    Data Strategy Expert
    Sage70, Inc.
    (917) 859-0151
    isaac@sage70.com

    Schedule a 30-minute consultation now:






  • 3.  RE: Right to Be Forgotten / Data Erasure Requests

    Posted 08-05-2021 07:46 AM
    I have had only one such request, and what we decided to do was to keep the identifiers and overwrite other fields with "REDACTED," while adding note(s) to the record on GDPR/Right to be Forgotten.

    Matt Bain
    Executive Director, Advancement Services
    Interim Director, Alumni & Constituent Engagement
    Division of University Advancement
    Kennesaw State University
    404-944-9130





  • 4.  RE: Right to Be Forgotten / Data Erasure Requests

    Posted 08-23-2021 09:51 AM
    Hi Greg....  

    Rutgers' University Foundation policy states we will keep enough information to honor the request for erasure: 

    Upon a request to erase information, we will maintain a core set of personal data to ensure we do not contact you inadvertently in the future or subsequently add additional data about you during a periodic update. The RUF/RUAA may also need to retain some information for legal purposes, including U.S. IRS compliance. In the event of an actual or threatened legal claim, we may retain your information for purposes of establishing, defending against, or exercising our rights with respect to such claim.

    Full policy: 

    Privacy Notice & Refund Policy | Rutgers University Foundation

    Terry Callaghan
    AVP, IT, Analytics & Gift Processing
    Rutgers University Foundation 

    aasp Executive Board


    ------------------------------
    Terry Callaghan
    AVP Information Technology, Records & Gift Process
    Rutgers University Foundation
    terry.callaghan@ruf.rutgers.edu
    ------------------------------



  • 5.  RE: Right to Be Forgotten / Data Erasure Requests

    Posted 08-23-2021 10:01 AM
    Hi Greg....  

    Rutgers' University Foundation policy states we will keep enough information to honor the request for erasure: 

    Upon a request to erase information, we will maintain a core set of personal data to ensure we do not contact you inadvertently in the future or subsequently add additional data about you during a periodic update. The RUF/RUAA may also need to retain some information for legal purposes, including U.S. IRS compliance. In the event of an actual or threatened legal claim, we may retain your information for purposes of establishing, defending against, or exercising our rights with respect to such claim.

    Full policy: 

    Privacy Notice & Refund Policy | Rutgers University Foundation

    Terry Callaghan
    AVP, IT, Analytics & Gift Processing
    Rutgers University Foundation 

    aasp Executive Board


      



  • 6.  RE: Right to Be Forgotten / Data Erasure Requests

    Posted 08-23-2021 09:52 AM

    Hey there. I think you meant to send this to Greg at TPL. Hope you are doing well.

     

    Chris