The Personal Data Access and Account Deletion Request Standard defines scope, roles and responsibilities, data deletion categories and workflows to process personal data access and account deletion requests.
This process applies to personal data requests submitted by both personal users or corporate GitLab.com SaaS subscription holders and customers. Account deletion requests for corporate subscription holders require validation and approval by the paid namespace account holder with a current GitLab subscription contract. As part of this approval process, the account holder of the paid namespace (owner) must remove the subscription holder (user account) from their paid namespace.
NOTE: If the user account is a free (personal) account, add the
account-deletion::personal label to the issue. If the user account is tied to a paid namespace with a signed contract in Salesforce (a corporate request), add the
account-deletion::corporate label to the issue.
|Support Team||Maintaining this deletion process handbook page and related deletion request project and issue templates|
|Support and Legal Team||Responsible for approving significant changes to this standard|
|Support and Legal Team||Responsible for approving exceptions to this standard|
|GitLab system owners||Processing user deletion for each system as required by the data deletion issue created through this process|
Under numerous global and national data privacy laws, users can request to have their GitLab.com accounts (and/or any other information that we have stored about them) deleted. They can also request to obtain more details about their data, including information about what data GitLab has stored about them.
Users requesting data deletion are required to confirm their intent to delete at the time of their request submission. For GitLab.com and full deletion requests only, form entries for username, email, and paid namespace memberships will be automatically validated. All other requests require manual review and validation (where applicable) until further improvements have been implemented.
Account deletion and data access requests go through a few stages before they can be closed.
You can use this main issue board to help track the progress of each request by filtering for issues assigned to you (typing in
Assignee = yourusername in the search field), or you can create your own issue board under the Account Deletion and Other Requests project, using the same labels to create lists for your own tracking purposes.
Users may send in deletion or personal data access requests in a few different ways, however the official request must be sent in through GitLab’s Personal Data Request form. The following walks you through how to handle submissions when requests come in through other channels.
When a request is received through a Zendesk ticket, do the following:
If a request to the Personal Account Requests Service Desk is submitted via email, update the issue with the following closure snippet, then add the
account-deletion::invalid label to the issue, and close it.
It looks like you've emailed this request in to us directly. In order for us to best assist you please re-submit this request via our [Personal Data Request form](https://support.gitlab.io/account-deletion/). Doing so will allow us to process your request more quickly and efficiently. This request will now be closed. We eagerly await your resubmission. Thank you!
NOTE: Requests sent in through the form will include a copy of the form entries in the initial description of the issue.
If the request submitted is spam, apply the label
Invalid Request::Spam, and close the issue.
Comments made in the issue will be emailed to the user. This is the only form of submission we will process. You will communicate with the user through the issue on the progress of their request.
If the user submits multiple requests, apply the
/duplicate marker to the duplicate issues, and respond with the following before closing the duplicates:
It looks like you have submitted multiple requests for the same purpose.
I'm closing this issue in favour of #123, and we will continue processing your request on the other issue.
Proceed with the request workflows to process their request.
Find the appropriate workflow below to process user submissions to our Personal Account Requests Service Desk, based on their request type. All requests must be filled within 30 days.
A user has the option to request deletion of the following:
Currently, only requests to delete a GitLab.com account or perform a full deletion are auto-checked upon form submission. Use the following workflows based on the type of deletion request submitted.
Use this workflow for requests to delete GitLab.com accounts or full deletion requests.
The following user entries are verified using built-in automated checks:
After submission, the automated checks will either fail or succeed.
If any of the automated checks fail, the user will receive an auto-generated response detailing the reason we are unable to process their request. The issue created will be marked as invalid with
Invalid request received noted in the title.
These issues are scheduled to automatically close, and the label
account-deletion::invalid will be applied. No action is required.
If all of the automated checks succeed, the user will receive a set of Verification Challenge questions in an auto-generated response. Users have a total of 14 days to respond to the challenge questions.
During this period, add the
Awaiting::Challenge Answers label.
If the user fails to respond after 14 days, apply the
Account Verification Failed label to the issue, and close it using the following snippet:
We have not heard back from you with responses to our verification challenge questions, which are required in order to verify your identity before we process your request. We will now close this request. If you still wish to proceed please feel free to submit a new request via our [Personal Data Request Form](https://support.gitlab.io/account-deletion/).
Once the user responds with their answers to the challenge questions, evaluate their answers using the Account Verification workflow with a data classification of
RED (all user data is classified as red) to confirm if the verification passes or fails.
If the user fails the challenge questions, apply the
Account Verification Failed label, and respond with the following snippet before closing the issue:
Unfortunately, the answers to our verification challenges have failed. As a result, we are unable to process your account deletion request. This issue will be closed.
If the user passes the challenge questions, proceed with processing their request by doing the following:
Thank you for stepping in the process with us to verify your account ownership. We have now started the process for the "type of deletion request".
Please note that it takes up to 30 days for the request to be processed as it's handled by different teams.
I will let you know once the deletion process is complete.
In the gdpr-request issue tracker, create a new confidential issue using one of the following templates, populating the title with the email address of the original request:
a. Deletion Meta Issue - Full template for full deletion
b. Deletion Meta Issue - GitLab-com template for GitLab.com account deletion
Follow the instructions in the top of the template, then complete each step in the issue that begins with
Support Engineer: in order.
An overview of this process is outlined in the chart below.
Use this workflow for requests to delete user data from the Portal (customers.gitlab.com).
Support Engineer:in order.
Use this workflow for requests to delete user data from Sales or Marketing systems.
Support Engineer:in order.
Users can request the following to obtain information about their data:
Use the following workflows based on the type of request submitted.
Use this workflow for requests to access full details about what data we have on the user.
Support Engineer:in order.
Use this workflow for general question submissions.
Exceptions to this procedure will be tracked as per the Information Security Policy Exception Management Process.