Updating email addresses, GDPR style

After scrambling to find a bandaid solution for the upcoming domainpocalypse caused by EURid, I set myself out tomake sure that all my accounts everywhere use a more stable domain. Some of you might have noticed, because it was very visible in me submitting .mailmap files to a number of my projects to bundle together old and new addresses alike.

Unfortunately, as I noted on the previous post, not all the services out there allow you to change your email address from their website, and of those, very few allow you to delete the account altogether (I have decided that, in some cases, keeping an account open for a service I stopped using is significantly more annoying than just removing it). But as Daniel reminded me in the comments, the Right to rectification or Right to correction, allows me to leverage GDPR for this process.

I have thus started sending email to the provided Data Protection contact for various sites lacking an email editing feature:

Hello,

I’m writing to request that my personal data is amended, under my right to correction (Directive 95/46/EC (General Data Protection Regulation), Article 16), by updating my email address on file as [omissis — new email] (replacing the previous [omissis — old email] — which this email is being sent from, and to which you can send a request to confirm identity).

I take the occasion to remind you that you have one month to respond to this request free of charge per Art. 12(3), that according to the UK Information Commissioner’s Office interpretation (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/) you must comply to this request however you receive it, and that it applies to the data as it exists at the time you receive this.

The responses to this have been of all sorts. Humans being amused at the formality of the requests, execution of the change as requested, and a couple of push backs, which appear to stem from services that not only don’t have a self-service way to change the email address, but also seem to lack technical means to change it.

The first case of this is myGatwick — the Gatwick airport flyer portal. When I contacted the Data Protection Officer to change my email address, the first answer was that at best they could close the account for the old email address and open a new one. I pointed out that’s not what I asked to do and not what the GDPR require them to do, and they tried to argue that email addresses are not personal data.

The other interesting case if Tile, the beacon startup, which will probably be topic of a separate blog post because their response to my GDPR request is a long list of problems.

What this suggests to me is that my first guess (someone used email addresses as primary keys) is not as common as I feared — although that appears to be the problem for myGatwick, given their lack of technical means. Instead, the databases appears to be done correctly, but the self-service feature of changing email address is just not implemented.

While I’m not privy to product decisions for the involved services, I can imagine that one of the reasons why it was done that way, is that implementing proper access controls to avoid users locking themselves in, or to limit the risk of account takeover, is too expensive in terms of engineering.

But as my ex-colleague Lea Kissner points out on Twitter, computers would be better at not introducing human errors in the process to begin with.

Have computers do the things computers are better at than humans: following rules repetitively and consistently. A ton of data protection and handling rules are better followed by computers than having humans in the mix.

— Lea Kissner (@LeaKissner) February 13, 2019

Of all the requests I sent and were actioned, there were only two cases in which I have been asked to verify anything about either the account or the email address. In both cases my resorting to GDPR requests was not because the website didn’t have the feature, but rather that it failed: British Airways and Nectar (UK). Both actioned the request straight from Twitter, and asked security questions (not particularly secure, but still good enough compared to the rest).

Everyone else have at best sent an email to the old address to inform of the change, in reply to my request. This is the extent of the verification most of the DPO appear to have put on GDPR requests. None of the services were particularly critical: takeaway food, table bookings, good tea. But if it was not me sending these requests I would probably be having a bad half an hour the next time I tried using them.

Among the requests I sent yesterday there was one to delete my account to Detectify — I have used it when it was a free trial, found it not particularly interesting to me, and moved on. While I have expressed my intention to disable my account on Twitter, the email I sent was actioned, deleting my account (or at least it’s expected to have been deleted now), without a confirmation request of any kind, or any verification that I did indeed have access to the account.

Maybe they checked the email headers to figure out that I was really sending as the right email address, instead of just assumed so because it looked that way. I can only imagine that they would have done more due process if I was a paying customer, if nothing else to keep getting money. I just find it interesting that it’s a security-oriented company, and didn’t realise that it’s much more secure to provide the self-service interfaces rather than letting a human decide, there.