Neil Pickstone
by Neil Pickstone 30 May 2018
compliance

26 people want to be forgotten

That’s the little big number so far across the Volcanic platform since last week; and that oxymoron really does sum up the mad rush post 25th May - Friday’s charge totalled 10 with further enthusiasm on the bank holiday being demonstrated by 5 requests.

But, it’s early days and when the mainstream media and consumer protection lawyers pick up the charge galvanised by the chance of class actions and new claims management companies rise from the ashes of PPI, we’ve no doubt that these little number will soon become big stats.

And regardless, getting one request is hard work. Volcanic received its first request over the weekend. Our system worked, ironically, you have to register with us to be forgotten, what can I say, we like records, audits, cause and effect, we’re technologists. But in the process of forgetting someone, we discovered that there’s a lot of human required, and this means time.

The person making the request’s email did not match the email we had on record, despite every other detail replicating our data on file. Because we knew that this was the same person, it would have been so easy to reply with the job being done, but because the email was different, we had to do a lot more heavy lifting to be sure that, unequivocally, the request being made was by the same person whose records we had on file. It was hard work! Sure, some of that is the nervous energy needed to ensure that we exercised the right right. Especially our first one.

 

The devil's in the detail

All I can say is, pay attention to the detail, be quick in your response. If you’re on the Volcanic platform, automated emails are generated to alert both the data representative and the data subject that the submission has been made - and the data rep will get a reminder if they have not processed the request seven days from the deadline.

But remember, there are probably more human touch points that will be needed - even if it’s an update to explain any potential issues or problems that are delaying the process. Remember that the spirit of the law is about transparency - use this to guide your interaction with the data subject.

If you need any more support let us know. We’ll also keep you posted on the numbers and our own experiences.

 
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