Overview

This document outlines the process for submitting GDPR delete and access requests via file uploads. It covers file formats, naming conventions, and provides examples for reference.

Request Types

• Delete Requests: For data deletion under GDPR

• Access Requests: For data access under GDPR

Where to Upload Files

• Delete Requests: Upload to the gdpr-delete/ folder in GCS bucket

• Access Requests: Upload to the gdpr-access-requests/ folder in GCS bucket

File Requirements

1. All files must be .csv format

2. No headers needed

3. One identifier per line

4. No special formatting or delimiters

File Naming Conventions

1. Phone Number Files:

   • Must include phone_number in the filename

   • Examples: phone_numbers.csv, phone_number_list.csv

2. Email Files:

   • Any name is fine

   • Examples: emails.csv, email_list.csv

   • Do not mix plain and hashed emails in the same file

Processing Schedule

• Weekday processing: 8 PM EST Monday through Thursday

• Weekend processing: 8 PM EST on Fridays

• Files are moved to a processed folder after processing

File Examples

1. Delete Requests (gdpr-delete/ folder)

A. Plain Email File (emails.csv)

user1@example.com
user2@example.com
user3@example.com
user4@example.com
user5@example.com

B. Hashed Email File (emails_hashed.csv)

e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855
a665a45920422f9d417e4867efdc4fb8a04a1f3fff1fa07e998e86f7f7a27ae3
b3a8e0e1f9ab1bfe3a36f231f676f78bb30a519d2b21e6c530c0eee8ebb4a5d0

C. Phone Number File (phone_numbers.csv)

+1234567890
+1987654321
1122334455
1555666777
1888999000

2. Access Requests (gdpr-access-requests/ folder)

A. Email File (emails.csv)

access1@example.com
access2@example.com
access3@example.com
access4@example.com
access5@example.com

B. Phone Number File (phone_numbers.csv)

+1999888777
+1777666555
1666555444
1555444333
1444333222

Important Notes

• The system automatically detects if a file contains hashed emails by checking if the first line contains an "@" symbol

• Phone numbers are recommended to be in E.164 format with country code (e.g., with '+' prefix)

• SHA-256 is the only supported hash format for email hashes

Common Mistakes to Avoid

• Including headers in the file

• Using wrong file extension (must be .csv)

• Mixing plain and hashed emails in same file

• Using wrong folder for request type

• Including empty lines or special characters

Troubleshooting

If files are not being processed:

1. Verify the file is in the correct folder

2. Check the file format (.csv)

3. Ensure the file naming convention is correct (for phone numbers)

4. Confirm the file is not empty

GDPR Request Processing Schedule

This section explains how GDPR delete and access requests submitted via file uploads are processed, focusing on the timing and automation of the process.

Processing Mechanism

• Automated Batch Processing:

  • All GDPR delete and access requests submitted through file uploads are handled by an automated system.

  • The system uses a scheduled job to process requests in batches, rather than processing each file immediately upon upload.

• Why Batch Processing?

  • Batch processing ensures efficient handling of large numbers of requests and helps maintain system stability.

  • It allows for consistent, predictable processing times and reduces the risk of errors from ad-hoc or manual processing.

Processing Schedule

• Daily Processing:

  • Processing runs once per day to process all new GDPR delete and access requests that have been uploaded since the last run.

• Processing Times:

  • Monday through Thursday: Processing occurs at 8 PM EST each day.

  • Friday (Weekend Batch): Processing occurs at 8 PM EST to cover the weekend period.

• No Immediate Processing:

  • Files uploaded will be processed during the next scheduled run.

  • If you upload a file after the daily processing time, it will be included in the following day's batch.

What This Means for You

• Plan Ahead: If you have urgent requests, please upload your files before the daily processing time to ensure they are included in the next batch.

• Confirmation: After processing, files are moved to a gdpr-processed/ for your reference.

• Support: If you have questions about the status of your request, please contact support with your file name and upload time.