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

submitted 2 years ago* (last edited 2 years ago) by malloc to c/reddit

157 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/

[2023-06-23 14:52 PDT] edit ~ formatting, fix title typo

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[–] thatwill 30 points 2 years ago (2 children)

I made a GDPR request through reddithelp.com last night; maybe I shouldn't have bothered! Assuming I don't hear back, I'll resend the request via email then report them to the Information Commissioner (UK gov dept) if I've had no proper response.

By the way, I'm not sure if the California law is the same, but with a GDPR "right to be forgotten" request, the organisation must delete your data from their backups (or at least make sure your data will not be restored from a backup). Asking you to delete your own comments clearly won't meet that requirement.

[–] Tired8281 14 points 2 years ago (1 children)

I'm gonna send mine registered mail. The way they have been behaving, I wouldn't put it past them to just send requests straight to the trash, then claim they never received them with a shit eating grin on their face.

[–] Lenny 2 points 2 years ago* (last edited 2 years ago)

Wish i did it via mail. There's no proof/track otherwise (unless you record it).

Requested my data last week. Does anybody know the legal timeframe for them to comply?

[–] [email protected] 1 points 2 years ago

Does Reddit have an email address for receiving such requests?