GDPR - Development Plan Data Deletion and Anonymization
When a user leaves a Legal Entity organizational unit (OU) and requests to be forgotten OR that user’s data is outside of the data retention period, development plans are impacted in the following ways:
- Individual Development Plans - If the user is the Development Plan Owner, the development plan is deleted. This includes if the user creates a development plan or is assigned a development plan.
- Development Plan Creator - If the user is a manager or administrator who created a development plan for another user, the user's core data such as First Name and Last Name is anonymized in the History section. This includes the Development Plan PDF.
- Development Plan Comments - If the user is a manager or administrator who has added comments to another user's development plan, the manager or administrator's core data such as First Name and Last Name is anonymized in the Comment section. This includes the Development Plan PDF. That is, the comments remain intact, but any references to the user are anonymized.
- Development Plan Templates - If the user has created a Development Plan Template, the development plan template is deleted.
When a data deletion request is made based on time, the development plan completion date is used to determine when the data is deleted or anonymized. If the development plan is not complete, then the development plan creation date is used.