GDPR Erasure Requests vs. Journey History and Suppression
A EU customer asks for erasure of all data. The contact has 14 months of journey history, 22 send logs, and is currently in a 6-week onboarding journey. Company policy is to retain send logs for 24 months for legal compliance and to keep a suppression record to avoid re-contact. Marketing Cloud's Data Retention Policy is set to delete send logs after 12 months, but legal wants 24 months. The admin must satisfy the erasure request without breaking reporting or re-contacting the person, and the contact is still active in the journey.
1. What data can be deleted, what must be retained, and how should the admin execute the deletion?
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Separate PII from legal records. Delete or anonymize the contact's profile attributes and any marketing data extensions that identify them. Retain the minimum suppression record-email address or a hash-because you need it to honor the opt-out and avoid re-contact; that is a legitimate legal basis. Retain send logs only if legal confirms a 24-month obligation, and restrict access. Execute by exiting the contact from the active journey, deleting the contact from All Contacts/Contact Builder, purging related data extensions, and confirming the suppression entry remains. Do not delete the suppression record as part of "all data" without legal sign-off; deletion would allow re-contact.
2. The contact is mid-journey. What are the options, and what are the risks of deleting the contact while the journey is active?
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Exit the contact from the journey first, or add the contact to a suppression/exclusion that prevents re-entry. Deleting a contact while the journey is active can leave orphaned journey history and, worse, the entry source may re-add the same person on the next evaluation, causing re-contact or errors. The safe order is: pause or version the journey if needed, exit the contact, add suppression, then delete the contact and purge data. Verify the entry source no longer includes them. If the journey is shared across many contacts, avoid pausing; use an exclusion criterion and test with a small audience.
3. How should the admin reconcile the 12-month Data Retention Policy with legal's 24-month requirement?
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Data Retention settings in Marketing Cloud permanently delete tracking data at the configured interval; they are not a legal hold. Check the age of the contact's send logs: if any are older than 12 months, they may already be gone and cannot be restored. Change the retention policy to 24 months before more data crosses the threshold, and document the change with legal's approval. Do not rely on the policy to preserve data for erasure requests-export or archive the send logs you are legally required to keep to a controlled store outside the retention window. Reconcile the policy against the retention schedule quarterly.