Reddit user alleges California Consumer Privacy Act (CCPA) non-compliance/violtion; and finds it difficult to delete posts and content on Reddit : reddit

this post was submitted on 26 Jun 2023

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Reddit user alleges California Consumer Privacy Act (CCPA) non-compliance/violtion; and finds it difficult to delete posts and content on Reddit (youtube.com)

submitted 1 year ago by [email protected] to c/[email protected]

140 comments fedilink hide all child comments

Video description as of 2023-06-23 10:15 PDT:

This video shows that Reddit refused to delete all comments and posts of its users when they close their account via a CCPA / GDPR request. Posts and comments may contain PII. Specifically, Reddit tells users that they must delete the content themselves, which isn't realistic if a user creates a lot of posts. Even if a user does delete their content, Reddit restores the content within a few days.

Video transcript:

2023-06-13 @ 15:15 PDT: user states he deleted all posts and comments
2023-06-16 @ 10:15 PDT (3 days later): user states all posts and comments have been restored
2023-06-19: user decides to submit a legal request under CCPA to delete content
2023-06-19 @ 11:07 PDT: user receives reply from "Reddit Legal Support" (RLS) which states they will delete the account but not the content associated with the account. It is up to the owner of the account to remove the content [e-mail contents reproduced below]

Reddit Legal Support (Reddit Support)
Jun 19, 2023, 11:07 PDT

Hello,

We would be happy to help you delete your Reddit account if you have one. Before we proceed please note:

 1. Account deletion is irreversible.
 2. Posts and comments must be separately deleted before deleting your account. If not separately deleted, the content of the posts and comments will remain visible and disassociated from any account. If you want your posts and comments removed, follow the instructions on our help page. 

Once the above mentioned information is removed to your satisfaction, please submit your deletion request by using your Reddit account and this form so we know it's really you making the request.

More information about account deletion is available in our Privacy Policy.

Kind regards,

Reddit Legal Support

2023-06-19 @ 12:02 PDT: user replies back to RLS stating it is unrealistic expectation for end user to manually delete and alleges violation of CCPA [reply reproduced below]

Hello,

If I understand your response properly, you are refusing to delete all data associated with my account. I believe this is illegal and in violation of the CPR. In this case the onus is on you, Reddit, to delete all of the content associated with my account. 

It is besides the point but last week I already deleted all of the posts and comments associated with my account. However Reddit has since restored most of the content.

It is untenable to demand all users to manually delete content when Reddit itself does not provide a self-serve mechanism to mass-delete content. Some users have thousands of posts and millions of comments. 

Just as a reminder, my CPA request to delete my account and all associated data was made on June 19th 2023 and
must be completed by August 3rd 2023.

2023-06-24 @ 10:45 PDT: user has not received a reply from RLS. He decided to painstakingly delete all posts and comments while screen recording the effort. Video continues with the user manually deleting posts for his account (https://www.reddit.com/user/nucleocide). Then fast forwards to the end of the segment where the last posts are deleted
2023-06-25 @ 10:25 PDT: user discovers posts and comments are restored, again

User concludes video and clarifies why this is a violation of CCPA:

At this point it appears impossible to manually delete posts and comments on Reddit and expect them to stay deleted. 

By not deleting all posts and comments in an automated way there is no way to guarantee that no PII [Personally Identifiable Information] has been left behind.

For example ...

<user gives example of a comment from 6 months ago on his account which includes his real first name and last name. Screen capture shows the comment was edited recently>

Since there is no guarantee that every single post and comment is free from PII, Reddit must delete all comments and posts from an account upon receiving a GDPR / CPA request.

Reddit Discussion on "/r/videos": https://old.reddit.com/r/videos/comments/14je01k/reddit_may_be_violating_the_fucking_ccpa/

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[–] [email protected] 5 points 1 year ago (1 children)

Quick question: is there any similar law in Australia?

[–] [email protected] 6 points 1 year ago* (last edited 1 year ago)

From my quick reading Privacy Act 1988 and GDPR are fairly consistent with eachother, but our legislation is a bit outdated. It seems to be amended every few months, but only in relation to niche clauses that cover very specific circumstances about someone in a particular role and their specific ability to interact with data.

-There is no distinction in Privacy Act between a data processor and a data controller. GDPR regulates individual responsibilities for both.

-In the Privacy Act there's nothing to stop multiple de-identified datasets from being cross referenced together in a way that could re-identify the data subject.

-The legal basis to protect consumers from collection of personally identifiable data is stronger under GDPR. The only thing an Aus organisation needs to do to collect sensitive data is establish that it's 'reasonably necessary' for their core business operation.

Also note that although GDPR is a European union regulation, many Australian businesses are still beholden to it, e.g. if they knowingly collect information from European customers or have a branch located in EU. You can't really have an EU branch that's GDPR-compliant if your parent company overseas isn't.