In preparation for the enforcement of GDPR which becomes final on the 25th of May 2018, I’m creating a simple, open-source forget-me app for springuni.com in compliance with Art. 17 GDPR (‘right to be forgotten’). In the first phrase, I’d like to support a simple forget-me process driven by the Scatter-Gather messaging pattern using Spring Integration and RabbitMQ, although I’ve got a ton of ideas about making a generally usable, granular, and flexible consent management app for fellow bloggers. Before going into coding the app instantly, in this article, I just set the initial requirements for myself and for starting a discussion if someone else is interested in having their own forget-me app.
Non-Technical Requirements
* GDPR is tricky in the sense that you have to delete folks’ personal data from all your systems, but you still have to be able to prove that you did comply with their request. Nowadays, one’s email address is the primary handle used to identify individuals and 90% of my subscribers use Gmail, 5% use Yahoo Mail, and the rest use other providers. Perhaps they are self-hosted. Having said that, the first requirement is to use social login backed by Google’s, Yahoo’s, and Facebook’s OAuth2-secured authentication flow. The last one would probably allow those people to login in, who use a customer email address of some kind. Spring Security 5’s new OAuth2 support will be just fine for the purpose.
* The app cannot persist personal data unless it’s absolutely necessary to carry the forget-me process out. Yet, it has to be able to state that the request of a certain individual has been successfully completed. By hashing (probably an SHA-2 variant will do) email addresses and creating a user profile without any personal details this requirement can be satisfied.
* Let’s think about the life-cycle of a subscriber’s subscription. Someone signs up for my newsletter, they may unsubscribe and eventually they may ask me to forget all their personal data stored. Given these three uses cases, a subscriber can be in the following states.
* SUBSCRIBED — denotes an active subscriber who gave their consent to receive newsletters.
* UNSUBSCRIBED — denotes an inactive subscriber, who withdrew their consent to receive newsletters.
* FORGET_PENDING — means that they requested that their personal data be erased with regards to a subscription
* FORGET_COMPLETED — means that personal data of a subscription has been deleted
* FORGET_FAILED — means that personal data couldn’t be deleted due to a technical issues https://goo.gl/Ec6B8v #DataIntegration #ML
