How to process a Right to be Forgotten request

Overview

Under the GDPR, contacts can ask for all the data you store on them to be deleted - which is known as a Right to be Forgotten request. The platform gives you the tools to ensure you can comply with this. 

Steps to process a Right to be Forgotten request

To delete the data you hold on a contact, follow the below steps for these four areas of the platform (should you hold data on your contact in all of these areas):

Contact data

  1. Go to Contacts, find the contact in question and select them to access the 'Manage contact' page.
  2. Select Contact actions in the top right and select Delete this contact.
  3. Before committing the action by selecting Delete, you'll be asked to confirm that you understand that: 
    • Deleted contacts will be removed from the address books they're currently in.
    • Undeleting contacts will not put them back in the address books they were in (they will only get added back to 'All contacts').
    • Deleted contacts are not unsubscribed, and that if they are re-added to your account they may receive campaigns. (If contacts do not want to receive campaigns, you should unsubscribe them instead).

Selecting Delete moves the contact to the Recycle bin for 30 days. After 30 days, all of their information held in Contact data fields and Insight data records will be permanently removed.

Only admin users have access to the recycle bin. Navigate to it by opening the settings menu in the bottom left corner of the app and selecting Recycle bin.

From here you can either permanently remove selected items or empty the entire recycle bin (enabling you to delete contacts before the 30 days are up), and, should you need to, you also have the option to recover (undelete) contacts that are in there. This can be done by either recovering all contacts via More actions > Recover all, or by making a selection (up to a maximum of 150) and selecting Recover.

recycle-bin.png

Pages and forms data

If the contact has submitted a response to any of your forms, you will need to follow the below steps to delete this data. You will need to repeat the steps for any of your forms that have responses:

  1. Go to Pages & forms > Reporting > Pages and forms and select the number in the Form responses column to open the Form report (if there is no number in the column, the form has no responses).Forms_reporting.PNG
  2. On the Reporting page, select the Responses tab.
  3. In the Search field, type in the contact's name or email address (whatever serves best to identify them based on the data you collected). If no results are returned, then you can move onto the next survey to search for the contact's data.
  4. Select the cross to the far right of any results returned for the contact to delete this data. Select Yes, delete this respondent on the warning that appears asking if you wish to continue. 

Surveys and forms data

The Surveys and forms functionality has been retired in favour of our Pages and forms tool, however you may still hold data on a contact in a Surveys and forms report, and this needs to be separately deleted to fully comply with their request.

To do so, follow these steps (which you need to repeat for each of your surveys in order to find out which ones your contact has responded to):

  1. Go to Pages & forms > Reporting > Surveys and forms (retired), and select a survey name to open the report.
    Survey_reporting.PNG
  2. On the Reporting page, select the Responses tab.
  3. In the Search field, type in the contact's name or email address (whatever serves best to identify them based on the data you collected). If no results are returned, then you can move onto the next survey to search for the contact's data.
  4. Select the cross to the far right of any results returned for the contact to delete this data. Select Yes, delete this respondent on the warning that appears asking if you wish to continue. 

This deletes all of the data held in a single survey for the contact. As mentioned above, you'll need to repeat the above steps for any of your surveys that have any responses.

SMS data

You may also hold data on a contact in the SMS tool, this also needs to be separately deleted to fully comply with their request.

To do this, follow these steps:

  1. Go to SMS, select Contacts, search for the mobile number belonging to the contact in question and check the box next to them
  2. Select Delete. Select OK when asked to confirm the deletion. 

This deletes all of the data held in this area of the platform for the contact.

Transactional email data

Finally, you may also hold the email address of a contact in the transactional email tool, this also needs to be separately deleted to fully comply with their request.

To do this, follow these steps:

  1. Go to Transactional email and search for the contact's email address at the foot of the dashboard. Do this for both 'Show successes only' and 'Show failures', to make sure you find any record of the email address. If no results are returned for either filter, then there's no data to delete for this contact.
  2. If results are returned, check the box to select all of the sends and then select Delete  

This deletes all of the data held in this area of the platform for the contact.

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