The GDPR 'right to be forgotten' provision has posed a problem for some accountants to fully comply, as they are unable to anonymise unwanted data from their cloud apps.
Practitioners have examined almost every conceivable angle of the ICO’s data protection regulation brought in on the 25 May, from reworking letters of engagement to emailing payslips, but one aspect that until now has been overlooked concerns what a business must do once the period for retaining information has passed.
An Any Answers thread uncovered the administrative quandary for accountants: how do you delete unneeded client personal data from cloud apps?
AccountingWEB regular Paul Scholes raised this query after a discussion with one of his cloud providers revealed the inability to delete data. This then leaves the business with the onerous task of manually deleting every customer or supplier to remove their information.
Scholes illustrated the need for this feature with a scenario where his client invoiced a personal customer in 2011, but since that person is no longer a customer, he argued that there is no reason to hold that personal data and he should delete it.
Some providers have options to ‘hide’ old users or ‘archive’ this information but as Scholes points out, this data would still be retained.
Instead, Scholes outlined the task now at hand: “I'd have to go in and change the names, and delete address, email address and, in some cases, if the software has kept a PDF on any invoices, these also have to be tracked down and deleted, so that the person could not be identified.”
Reasons why this is not clear-cut
Taking payroll as an example, Karen Bennett from payroll software Brightpay, who wrote an industry insight on this subject, told AccountingWEB that like anything concerning GDPR there are considerations that don’t make this scenario clear-cut.
“With BrightPay Connect, our cloud self-service portal, employers or accountants can restrict access for an employee or group of employees,” said Bennett. “For leavers, there is an option to restrict their access, but an employer (or accountant on their behalf) must keep their information for the statutory periods required by law.”
When that is the case the information is maintained or archived on the software. Where a customer wants to completely remove all data for an employer, this can be removed via their payroll bureau online dashboard, but there are other manual options available. “If they want to remove a particular version of an employer file they cannot do this themselves, this is available on request,” added Bennett.
Solutions are coming
Where there isn’t a requirement to maintain the data, some software providers have actually released updates to resolve this issue. Sage Business Cloud, for instance, is one provider that is supporting the GDPR right to be forgotten. In its 16 May update, the software included the functionality discussed in the thread to ensure that the user's contacts’ details are no longer identified.
Pandle will also be adding this ability to remove personal data without affecting transactions. “Effectively the personal data will become anonymous," Pandle's founder Lee Murphy told AccountingWEB.
Explaining Pandle’s approach to this aspect of GDPR, Murphy said: “Under GDPR companies should only keep personal data as long as is necessary. HMRC requires companies to keep records for a period of six to seven years, but after this time there is unlikely to be a good reason to hang on to personal data for old customers.
“That’s why at Pandle we are developing a tool to enable users to remove their customer and supplier details without having an adverse effect on transactions, essentially anonymising customer and supplier data.”
But in lieu of an updated solution from all chosen software providers, AccountingWEB ShayaG suggested a short-term solution: change the customer’s name to “Oldcustomer_1” and delete their address and contact information.
Bobby Chadha, senior manager at Propel by Deloitte, told AccountingWEB that one of the risks in removing data from cloud apps is that it’s removed.
“Imagine a scenario where as an accountant you have had a client on a cloud-based solution leave you or done a runner,” he said. “If you're paying for the subscription, you then cancel it. Some software providers will provide a year for you to download your transactions in CSV format and after 12 months it is then deleted.
“The headache occurs if no action was taken during this period and the file was subsequently deleted meaning all the transaction info is also deleted and the client then reappears needing it.
“Vendors should look to provide an easy download feature of all transactional data in their software and should also prompt users to download their data if they cancel their subscription.”
He added that firms should build this aspect into their client exit process. “Remember to download the relevant transactions from the software and send it across to the ex-client or to communicate with the ex-client to log in to their software to download their data (email creates an audit trail so avoid phone calls).”
Has your software been updated to help with this quandary? Have you found an alternative solution? Or are you still bamboozled by this problem?
About Richard Hattersley
Richard is AccountingWEB's practice correspondent. If you have any comments or suggestions for us get in touch.