R317. Allow erasure requests

Requirement

The system must allow users to request erasure of data belonging to them that it is managing.

Description

Systems usually request information from the users, obtain it from third parties or collect it based on their interactions with the application. They should have a mechanism that allows users to request the erasure of this information and guarantees its complete deletion. Furthermore, the erasure should also occur if the user decides to revoke their consent.

Exceptions

  1. If the system is able to demonstrate that it is not possible to individually identify the users based on the information collected from them, this requirement is not applicable.

References

  1. CWE-212: Improper Removal of Sensitive Information Before Storage or Transfer. The product stores, transfers, or shares a resource that contains sensitive information, but it does not properly remove that information before the product makes the resource available to unauthorized actors.

  2. GDPR. Art. 11: Processing which does not require identification.(2). Where the controller is able to demonstrate that it is not in a position to identify the data subject, articles 15 to 20 shall not apply.

  3. GDPR. Art. 17: Right to erasure (‘right to be forgotten').(1). The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay.

  4. ISO 27001:2013. Annex A - 18.1.4 When applicable, guarantee the privacy and security of personal information, as required by the relevant legislation and regulations.

  5. OWASP-ASVS v4.0.1 V8.3 Sensitive Private Data.(8.3.2) Verify that users have a method to remove or export their data on demand.

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