Data Decommissioning – Destruction of Accountability

Subsequently, with this in mind, when a pro bono opportunity to assist with a humanitarian disaster relief effort presented itself, I proposed a data destruction caveat for the contract. While the customer didn’t seem to care much one way or another, I was excited to learn the customer agreed to the wholesale destruction of the aggregated data set upon project closure. And delete it all we did.

A small victory for privacy it seemed – that is, until a few years later when I realized that I could no longer prove what was done, right or wrong. In fact, had there been any after-the-fact disputes about incorrect action taken based on the recommendations of the technology, I would have had to say, "We destroyed the evidence!"

In summary, when designing systems which require strong audit, accountability and repeatability processes … very careful consideration must be given to delete processes.

Deeper Technical Points:

1. Much like the challenges that come with processing deletes, record changes can have the same issues. This occurs when a system overwrites changes rather than keeping each incremental record state and its temporal relevance. When overwriting changes – one is deleting previous values; it is this de facto deletion that compromises audit and accountability processes.

2. A further complicating factor is that not all changes are the same. Some changes are corrections, i.e., the earlier value was incorrect, e.g., wrong driver’s license number or a missing apartment number in an address. Another type of change is one where a value supersedes a previous value, e.g., when recording a married name, new email address, or new cell phone number. Further complicating matters, most systems of record do not have a mechanism to capture the difference between corrections and updates – forcing system designers to make some assumptions.

3. When synchronizing data across information sharing environments, propagating deletes through this ecosystem forces each receiving party into this same accountability dilemma.