DPA case Inquiry into Apple Distribution International Limited - March 2024 – Complaint Upheld (Ireland, 2024)
General GDPR enforcement action
This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.
Apple was found to have kept a hashed version of a user's email address even after they requested to delete their account. The DPC is investigating whether this retention was lawful and if Apple properly informed the user. This case underscores the importance of honoring user deletion requests.
What happened
Apple retained a hashed version of a user's email address after they requested account deletion.
Who was affected
A user who requested the deletion of their Apple ID and later found their email address still linked to another account.
What the authority found
The DPC is examining whether Apple had a valid reason for keeping the hashed email address after the user's deletion request.
Why this matters
This inquiry highlights the necessity for companies to clearly communicate their data retention practices and comply with deletion requests from users.
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On 3 March 2019, a data subject made an erasure request to Apple (the controller) in respect of his Apple ID. The controller confirmed that it was handling the erasure request and stated that when the account was deleted, the data stored with Apple would also be permanently erased. However, the controller continued to retain a hashed value of the data subject’s email address. It did not inform the data subject that it would retain this data. The data subject later attempted to create a new Apple account using his email address, and was notified by Apple that the email address could not be used as it was already linked to another Apple account. Realising his deletion request had not been honoured, the data subject filed a complaint with the Irish Data Protection Commission (DPC) on 25 October 2021. The DPC commenced an inquiry in November 2022. In response to the complaint, the controller submitted that it had retained this data for the purposes of its legitimate interests, including to be able to demonstrate compliance with its security obligations under Article 32 GDPR, prevent recycling of namespaces by users, protect users against fraud and security breaches by third parties, and demonstrate compliance with a user’s request to delete their Apple ID. While the period of retention was not yet certain, the controller informed the DPC that it convened with its security teams to review the period for deletion at some fixed time. The DPC’s inquiry considered the following: * Whether the controller had a lawful basis for retaining the hashed email address after an Article 17 GDPR erasure request had been made; * The period for which the controller intends to retain the hashed email address; * Whether the controller met the obligations in Articles 12(1) and 17(1) GDPR in processing the erasure request; * Whether the controller complied with principles of transparency in terms of notifying the data subject of the retention of the hashed email value. The DPC found that
Outcome
Complaint Upheld
A data subject complaint that was upheld by the DPA.
Related Enforcement Actions (0)
No other enforcement actions found for DPA case Inquiry into Apple Distribution International Limited - March 2024 in IE
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. DPA case Inquiry into Apple Distribution International Limited - March 2024 - Ireland (2024). Retrieved from cookiefines.eu
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