Map copies, define retention, and test the erasure-request: Which evidence should resolve approval of the
A defensible process must connect data location, retention rules, and tested rights-request execution across the lifecycle.
The question
Under the GDPR, a customer-service model copies conversations into training datasets and operational logs. A customer requests erasure, but the organization cannot identify all copies or explain retention periods. Which evidence should resolve approval of the handling process?
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- Collect a vendor statement that deletion is technically supported.Vendor capability does not show where organizational copies exist, which retention rules apply, or how the request will be handled across systems.
- Map copies, define retention, and test the erasure-request workflow. ✓This evidence connects storage locations, storage limitation, and practical rights handling across training datasets and operational logs.
- Ask customer-service supervisors to approve each deletion request manually.Supervisor approval may add review, but it does not identify all copies or establish consistent retention and erasure execution.
- Publish a general privacy notice describing model improvement purposes.Transparency supports fairness, but a notice does not map copies, establish retention controls, or demonstrate request execution.
The trap
For rights questions, prioritize data mapping plus executable workflows, not notices or isolated vendor capabilities. How to remember it
A defensible process must connect data location, retention rules, and tested rights-request execution across the lifecycle.
How many of these would you get right?
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