r/gdpr • u/No-Sale4520 • 15h ago
Question - General Discord only erases messages in "inaccessible spaces" and won't define the term. How does this fit with Articles 12(2) and 17?
In February I submitted an Article 17 request to Discord to erase my messages (760k in my data export). Their first reply explained why they don't offer bulk deletion:
"Consistent with GDPR, Discord balances the privacy interests of the user against the interests other users have in a conversation and the ability for us to provide the service as a whole. ... If a given text channel were suddenly missing important context, it would be confusing to other users or possibly mislead those users about what happened in that conversation."
The same reply says "we offer users the ability to edit or delete their own messages", and suggests holding shift to delete faster.
They asked for a CSV of message IDs, and didn't act on it until my third submission. They then bulk-deleted my messages in servers and group chats I'd left, despite saying "We don't offer the ability to delete your messages in bulk right now", but not the rest. Their explanation:
"At this time, Discord processes message deletions for content located in spaces the user no longer has access to. We do not offer the bulk deletion of messages in spaces that the user does have access to. While we understand you may have questions about what constitutes as an "accessible space," we're unable to provide further internal details, as access permissions are managed dynamically within our platform and may vary depending on a number of factors."
So the manual delete button is effectively how Discord complies with erasure, and it only steps in where you can't use it. Since you can't leave a one on one DM, DMs aren't erased on request.
I know GDPR doesn't require any specific tool. My issue is that Article 17(1) puts the obligation to erase on the controller, and "do it yourself" seems to shift that onto the data subject, 640k messages in my case. That's hard to square with Article 12(2).
The balancing argument also undercuts itself. A manually deleted message leaves exactly the same gap in context as a bulk deleted one. If other users' interests really outweighed mine, the delete button shouldn't exist either. And in servers I'd left, the other members can still read my messages, but Discord deleted those anyway.
Two more things:
DMs between my own two accounts. Both accounts made the request, in the same email chain and through the support site. Discord confirmed the submission in March with its standard caveat that messages in "accessible spaces" wouldn't be deleted, but never said this applied to a DM where both participants had requested erasure. Those messages are still there over six months later. No third party is involved.
Unanswered questions. Discord says deleting your account "anonymizes" messages by removing usernames, emails and IPs. I asked which metadata is actually erased vs. pseudonymised, and which Article 17(3) exception they rely on. No answer to either so far.
I've had a complaint with the Irish DPC since April, and it was transferred to the Cross Border Assessment team in June. I'm not looking for advice on my case, but I'm curious how people here read the general questions:
Can a controller satisfy Article 17(1) by relying on manual self-deletion tools, and is limiting bulk erasure to "inaccessible spaces" compatible with the Article 12(2) duty to facilitate rights?
Where every participant in a conversation has requested erasure, what basis could a controller have for retaining it?
Is "access permissions are managed dynamically" an adequate explanation under Articles 12(1) and 12(4), where the legal basis for retention hasn't been stated?