GDPR-003 critical Right to Be Forgotten
Deletion timelines defined
GDPR requires response within one month. Define and communicate timelines, track requests against deadlines.
Question to ask
"Deletion request arrives today — when is it done?"
Verification guide
Severity: Critical
GDPR Article 17 requires response "without undue delay" and within one month. You need defined timelines and tracking.
Check automatically:
# Look for timeline/SLA documentation
grep -riE "30.*day|one.*month|deletion.*timeline|response.*time|sla.*delet" docs/ README.md CLAUDE.md --include="*.md"
# Check for automated reminders or deadline tracking
grep -riE "deadline|due.*date|sla|remind.*delet" src/ app/ --include="*.ts" --include="*.js" --include="*.py"
Ask user:
- "What's your committed timeline for completing deletion requests?"
- "Is this documented anywhere users can see? (privacy policy, terms)"
- "Do you track against this timeline? (alerts if approaching deadline)"
Legal context: GDPR requires response within one month. Can extend by two months for complex requests but must notify user within first month.
Pass criteria:
- Timeline defined (typically 30 days, max 90 for complex cases)
- Timeline communicated to users (privacy policy or confirmation email)
- Internal tracking to meet deadlines
Fail criteria:
- No defined timeline ("we get to it when we can")
- Timeline exists but not tracked
- Regularly exceeds GDPR limits
Evidence to capture:
- Defined timeline (days)
- Where timeline is documented (internal + user-facing)
- Tracking mechanism for deadlines