Reddit user alleges California Consumer Privacy Act (CCPA) non-compliance/violtion; and finds it difficult to delete posts and content on Reddit

malloc@lemmy.world to Reddit@lemmy.world – 188 points –
Reddit violates CCPA
youtube.com

Video description as of 2023-06-23 10:15 PDT:

This video shows that Reddit refused to delete all comments and posts of its users when they close their account via a CCPA / GDPR request. Posts and comments may contain PII. Specifically, Reddit tells users that they must delete the content themselves, which isn't realistic if a user creates a lot of posts. Even if a user does delete their content, Reddit restores the content within a few days.

Video transcript:

  • 2023-06-13 @ 15:15 PDT: user states he deleted all posts and comments
  • 2023-06-16 @ 10:15 PDT (3 days later): user states all posts and comments have been restored
  • 2023-06-19: user decides to submit a legal request under CCPA to delete content
  • 2023-06-19 @ 11:07 PDT: user receives reply from "Reddit Legal Support" (RLS) which states they will delete the account but not the content associated with the account. It is up to the owner of the account to remove the content [e-mail contents reproduced below]
Reddit Legal Support (Reddit Support)
Jun 19, 2023, 11:07 PDT

Hello,

We would be happy to help you delete your Reddit account if you have one. Before we proceed please note:

 1. Account deletion is irreversible.
 2. Posts and comments must be separately deleted before deleting your account. If not separately deleted, the content of the posts and comments will remain visible and disassociated from any account. If you want your posts and comments removed, follow the instructions on our help page. 

Once the above mentioned information is removed to your satisfaction, please submit your deletion request by using your Reddit account and this form so we know it's really you making the request.

More information about account deletion is available in our Privacy Policy.

Kind regards,

Reddit Legal Support
  • 2023-06-19 @ 12:02 PDT: user replies back to RLS stating it is unrealistic expectation for end user to manually delete and alleges violation of CCPA [reply reproduced below]
Hello,

If I understand your response properly, you are refusing to delete all data associated with my account. I believe this is illegal and in violation of the CPR. In this case the onus is on you, Reddit, to delete all of the content associated with my account. 

It is besides the point but last week I already deleted all of the posts and comments associated with my account. However Reddit has since restored most of the content.

It is untenable to demand all users to manually delete content when Reddit itself does not provide a self-serve mechanism to mass-delete content. Some users have thousands of posts and millions of comments. 

Just as a reminder, my CPA request to delete my account and all associated data was made on June 19th 2023 and
must be completed by August 3rd 2023.
  • 2023-06-24 @ 10:45 PDT: user has not received a reply from RLS. He decided to painstakingly delete all posts and comments while screen recording the effort. Video continues with the user manually deleting posts for his account (https://www.reddit.com/user/nucleocide). Then fast forwards to the end of the segment where the last posts are deleted
  • 2023-06-25 @ 10:25 PDT: user discovers posts and comments are restored, again

User concludes video and clarifies why this is a violation of CCPA:

At this point it appears impossible to manually delete posts and comments on Reddit and expect them to stay deleted. 

By not deleting all posts and comments in an automated way there is no way to guarantee that no PII [Personally Identifiable Information] has been left behind.

For example ...

<user gives example of a comment from 6 months ago on his account which includes his real first name and last name. Screen capture shows the comment was edited recently>

Since there is no guarantee that every single post and comment is free from PII, Reddit must delete all comments and posts from an account upon receiving a GDPR / CPA request.

Reddit Discussion on "/r/videos": https://old.reddit.com/r/videos/comments/14je01k/reddit_may_be_violating_the_fucking_ccpa/

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Decided to expand on the original video and include a transcription of the events in the video. Hope this helps our visually impaired folks.

Personally, I find this disgusting. Hope Reddit gets litigated up the ass.

Good work on the transcription, it must've taken a while to do.

Normally, transcription like this will take a long time. However, since it's largely text based (e-mails, viewing reddit) and relatively short. It was pretty easy to transcribe to text. With the help of some macOS features like copying and pasting from video, it became a non-trivial task.

I think I spent more time on formatting rather than on transcription.

I think you meant ‘it be came a ~non-~trivial task’. At least that fits more with that paragraph’s overall sentiment.

Anyway, thanks for the work. I much rather skim a text than watch a YouTube video.

My grammar took a nose dive after transcription 😅. I fixed it. Thx

Seriously, thank you for that extra mile. This is the kind selflessness that I remember on the old internet

Thank you. I’m not visually impaired but I have cognitive issues that make watching videos difficult. I appreciate your time and effort 😊

This seems enough to me to sue them on grounds of violating the GDPR. Not sure where spez is going with this but paying GDPR fines will most definitely not do any good to reddit's profitability lol

How does one go about holding a US based company accountable violating an EU law that they aren't required to comply with?

They are required to comply with it if they want to offer services to European customers. If they don't comply with the local regulation they will face fines and if they don't pay them and become compliant, they might have their access blocked from within the EU.

Adding to this, while there are certainly ways to bribe the Brazilian regulatory and supervisory bodies, they're pretty damn heavy handed and pro-consumer to begin with. One agency has recently fined Netflix for their bait-and-switch marketing to what is estimated as several hundred million USD, with even bigger fines to come.

Has this ever actually happened?

In Europe fines have been dealt but no blocking yet as far as I am aware. Just the fine and threat of a block happening is usually enough to make companies comply because they don't want to lose out on the market share.

Edit: Link to Europe statistics: https://www.privacyaffairs.com/gdpr-fines/

A lot of US news sites are blocking themselves out of Europe instead of complying.

I don't think that's something that Reddit would do. They currently have offices in Dublin and Amsterdam, they clearly have an interest in the European market.

A lot of local.usa news sites region block EU ipaddresses to premptivly as they do a lot of tracking.etc that would.violate it so they just chose not to have the hassle of eu visitors

Yeah I read about that but it seems to be voluntary. I haven't read anything about anyone actually being blocked, but it seems to be because the threat of a fine and blocking is enough. Another commenter pointed out they have offices within the EU so I guess EU officials could chase them up there.

So Brazil has the equivalent of China's firewall? Or is this something implemented at the ISP level?

It's implemented at the ISP level, Brazilian courts can mandate all nationally operating ISPs and mobile carries to block certain websites or services if they fail to comply with for example a judicial warrant. This has happened twice with WhatsApp for instance, and Telegram was threatened with it as well because they refused to hand over the identities of neonazi domestic terrorist groups.

You can easily go around that with a proxy btw.

I am aware, but businesses generally don't want their users to jump through hoops to be able to access their services.

The average user doesn't even know what a proxy is. At that point, you've killed profitability.

They are required to comply with the GDPR to operate in Europe.

Even more, they are required to comply if they target European countries as a market. For example, if you have registration open and you have translations in - say - French, Italian, German etc. It is already enough to force you to comply, as there is the clear intent of targeting European users.

The same way they have with Facebook, Google etc. If they continue to do business in Europe with European users, they comply with European law or get fined significant amounts.

It's either comply with laws regarding EU users or get blocked from operating in EU countries, I'm not sure of the entire process though

Reddit has its European headquarters in Ireland... And its absolutely legally required to follow our laws.

That Irish sandwich corporate structure (that's really a thing , I'm not making it up) to dodge taxes is coming home to bite them in the ass. How delicious..

Yeah, they have to obey the law wherever they operate.

Internet empires like Facebook and Reddit have a lot of grey area to be honest

Discord is worse. At least Reddit lets you delete everything you post. With Discord, if you are banned from a server, then there is no way to delete your posts in that server. That is insane to me in this day and age.

Yes, reddit let's you delete everything you post but then they secretly repost it all a few days later. I'd argue that's worse because they make you think it's deleted but it's not.

This behavior is demonstrated in the video and many other reddit users have posted similar complaints recently. I have personally experienced the same issue.

I agree that if Reddit is doing that, then that is unacceptable. I have no reason to doubt it, but I have not experienced it myself.

At least Reddit lets you delete everything you post

Only the last 1000 comments or so. Earlier comments get dropped from your user profile and become virtually inaccessible, only findable with a google search.

Also, comments from closed subreddits are inaccessible to you, but still there (i.e. when the subreddit reopens, they will become available again).

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That's insane. I'm no lawyer but I've used the CCPA to get my info removed from a lot of those data-broker sites. It's always immediate, "Okay, we've removed your information." California better hit Reddit hard for this, and Europe too.

I made a GDPR request through reddithelp.com last night; maybe I shouldn't have bothered! Assuming I don't hear back, I'll resend the request via email then report them to the Information Commissioner (UK gov dept) if I've had no proper response.

By the way, I'm not sure if the California law is the same, but with a GDPR "right to be forgotten" request, the organisation must delete your data from their backups (or at least make sure your data will not be restored from a backup). Asking you to delete your own comments clearly won't meet that requirement.

I'm gonna send mine registered mail. The way they have been behaving, I wouldn't put it past them to just send requests straight to the trash, then claim they never received them with a shit eating grin on their face.

so the CEO known for sharing pornographic pictures of minors online does not respect people's privacy after all? who would've thought

I’m OOTL, spez did what now?

Spez was a mod of /r/jailbait

Worth noting that at the time users did not need to agree to be a moderator, it could be thrust upon them. I've heard that he had comments both on the sub and comments defending it, but have not personally seen any proof of that.

It's not strictly untrue, but it has implications that I don't personally quite believe (though I'm willing to change that opinion if somebody has evidence).

Back in the day invitations to be a mod were auto-accepted so the mod of /r/jailbait added him to the modlist

The guy's a crappy CEO I'm not sure why people have meme about stupid shit like the above to distract from that especially on the fediverse which has it's share of questionable content

Spez was a mod of the jailbait sub before the corporate buyout shut it down. Technically we don't know if he shared any pictures, but we know he was a mod at one point.

He's a piece of shit, but worth noting he was a mod of /r/jailbait at a time that mod requests sent to users were auto-accepted. He did not need to actively do anything. All he needed to do was ignore his Moderator privileges and inbox for a while.

It should also be said that back then you could nominate users to be a mod and appoint them without their input.

Well shoot. I'm in California these days and recently deleted all my comments on Reddit. I'll have to monitor and see if they come back...

Lots of zombie posts. I had to run power delete every day for 7 days before it stopped seeing posts reappear.

Interesting, from a GDPR perspective this is unacceptable.
Pondering about a proper GDPR complaint.

some of my old reddit accounts might have > 1000 comments.

The video creator appears to be from California, since he was trying to claim account deletion under CCPA. If reddit legal support is also slow rolling account and associated content deletion as well for GDPR, then the legal blowback could be massive.

I assume that they just don't have the infrastructure to do it, otherwise they would just use GDPR code for CCPA.

As a software developer: GDPR was a real pain to refit into an old legacy system. It's less of a pain if you know beforehand and can plan ahead.

Would suck if they had to spend money on the infrastructure to mass-delete data that the deletion of lessened their value to investors.

Shame.

It's a flawed risk assesment.
short term not complying is much cheaper. long therm it's bad, but for the individual : "whatever, I got my bonus and switched to another position"

It's actually a risky game. It doesn't happen often, but under GDPR not complying can result in the stop of data processing. It happened recently with Italy and OpenAI for example. If that happens, reddit would be forced to stop processing any data from people coming from that particular country, or countries, because each data protection authority can act. Of course that is the equivalent of a nuke, but it can happen, and if it happens I am not sure anybody is getting bonuses soon...

My account is 16+ year old and has 300 k combined karma. I will be sure to contact my data protection officer to complain. Reddit needs an audit to document they wipe the db properly, and the data is gone from backups. Not just my data, anything they got on me.

After seeing the comments above, I was about to say precisely this. Getting the data protection authority involved is the most sensible way.

I really hope the GDPR is put to full use here.

I'm curious though, what would happen if someone sent a GDPR deletion request to a Lemmy instance? The server admin would then delete the posts and account, but what if some other instances had defederated after the user made the posts, how would it be possible to make sure the posts are deleted from those instances as well? In theory that could be hundreds of servers. I guess the user would have to reach out to each instance?

Good question. Yes, it would be much harder because you're basically shotgunning your posts all over the place when posting here. I would think it's pretty much impossible to make sure that every single instance of it is gone.

As far as I can tell, GDPR is a defense against corporations who claim to own your data, and hold that data hostage. But it's not a infallible tool to scrub data from the internet.

Think about a tweet that's been screenshotted throughout the Internet. Twitter would have to delete the original post and and data they control, but I imagine they have no liability for the outsiders taking screenshots.

How GDPR applies to Lemmy may have to be explored in court.

But I'm just a layperson without specific knowledge of the law, so that legal framework may already exist.

That is crazy. I spent hours one week ago deleting manually all my comments. I had an empty profile. After reading this post I checked my account and all my comments are back. That is crazy. What a shit company. I’m hesitant to submit GDPR request since I feel like I’ll lost account access with comments still visible…

I guarantee most power users are the ones who are upset about this change. Losing decades of content they created for free hurts reddit unimaginably. How many articles have you seen about SEO ruining Google and needing to append 'reddit' to searches?

Power users deleting their content ruins that search engine to reddit pipeline.

Tried this last night and my posts are back too. Thinking about editing each and replacing with some shit about spez. That will surely get it removed

Keep upvoting for algorithm. Keep updating to never die. Keep disseminating to those unheard. Keep EDUCATING. So people on Internet will eventually get ourselves the insight to ponder and make (mass and individual) actions on ourselves (cause only us the mass will steer a happening and slap his stubborness).

Should never let this go down and covered.

I bet that this video/problem will never solve/succeed if people do not become considerate and woke but just read and passby from this. Protests seem not working to my perspectives. But, mass (compliant and infallible) actions ensures changes.

Was this written by an AI?

This is for the first time in my real Internet life that someone interrogates my comment (maybe also my real existence) whether if it's written by AI or not. 🤣😂🤯😭

Lololol but so sad and eerie that netizens have begun to fear of contexts and contents they see on Internet and offline+tangible media probably maliciously generated by AI I hope not (I understand and also experience).

I should embrace and be cleverly prepared to this hardly grasped phenomenon that I've been worrying of and never been liking, to my perspective, the coming of real cultural information age.

I'm autistic and this definitely reads as someone on the spectrum, not someone purposefully trolling. Autistics do get a lot of AI likeness though.

Apologies if you are not on the spectrum.

It's funny. I got a little drunk and posted something on Reddit I really ought not have. I went back a day later and deleted it. A day after that, the comment came back, and I was suspended for three days over it. If you hadn't brought that comment back from the dead, this wouldn't even have happened, but okay, whatever. It wasn't like I wanted to spent too much time at Reddit after the lemur-eyed, horse-teethed worm told us how expendable we all are as users.

Quick question: is there any similar law in Australia?

From my quick reading Privacy Act 1988 and GDPR are fairly consistent with eachother, but our legislation is a bit outdated. It seems to be amended every few months, but only in relation to niche clauses that cover very specific circumstances about someone in a particular role and their specific ability to interact with data.

-There is no distinction in Privacy Act between a data processor and a data controller. GDPR regulates individual responsibilities for both.

-In the Privacy Act there's nothing to stop multiple de-identified datasets from being cross referenced together in a way that could re-identify the data subject.

-The legal basis to protect consumers from collection of personally identifiable data is stronger under GDPR. The only thing an Aus organisation needs to do to collect sensitive data is establish that it's 'reasonably necessary' for their core business operation.

Also note that although GDPR is a European union regulation, many Australian businesses are still beholden to it, e.g. if they knowingly collect information from European customers or have a branch located in EU. You can't really have an EU branch that's GDPR-compliant if your parent company overseas isn't.

Is anyone surprised at this?

I think Reddit should be forced to retroactively delete all comments and post history from users who have since deleted their account. If the user account was deleted, there is no reason they should be allowed to keep the data on that deleted account, period.

At the very least a company should be required to give the option to nuke your data when deleting an account. Not sure if this exists in any legislation but would be useful.

Not really. The list of controversies from reddit have continued to increase since 2014. The latest controversy was just the last straw that broke the camel's back.

Personally, I am not familiar with CCPA, so I can not really comment on the justifications claimed by the video creator. But the fact that reddit legal support is slow rolling the deletion of the content generated is just scummy.

Worth noting Colorado and very recently Connecticut have similar laws, so the complaint could be leveraged from multiple states.

One other thing to note is that many of these companies don’t even try to determine if you live in California or not. I have worked for two large tech companies on data governance issues and we didn’t even bother to check. If we got a request we would comply with CCPA. It was not worth the potential fines to try and only comply with CA residents. Reddits whole business model is based on that data though so they may deem it worth the effort.

Is there bot / tool to edit my reddit posts in batch ? Seems that editing could be harder to mass reverse as it requires someone to review if the edit was for better or worse.

Alternatively to keep on deleting my reddit posts every day ?

PowerDeleteSuite on GitHub

Unfortunately this doesn't get past the 1000 comment limit. I've found lots of my old comments still on Reddit. Does anyone have another solution?

I’ve heard good things about redact.dev

react.dev worked really well for me, be warned though some subs ban you for using it. I was banned from r/funny for removing my posts, a couple of others banned me too but don't think they were big names/ as well known as rfunny

Does it matter if they ban you if you are planning on leaving anyways?

it was just a cautionary message for anyone else looking to use the same app.

I am right this second in the process of using PowerDeleteSuite to edit all my old reddit comments to be ads for lemmy

Edit: huh but it only worked okay, successfully replaced about 1/4 of my old comments after running it a few times. Any recommendations from those who have had more success?

I've run it about a dozen times over the past few weeks, it misses different comments and also comments get restored to previous versions (i.e. back to the original or to one of the earlier overwrite pass versions). At this point I don't have any comments in my profile that aren't at least some version of the overwrite message but I also manually deleted a bunch of comments that either were restored or were missed during an overwrite pass. It seems like at least once a day something gets reverted or restored but I haven't been paying close attention. My plan is to check again in a few days and probably run it a few more times.

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Alternatively to keep on deleting my reddit posts every day ?

Late to the game here, but that's the approach I've gone with. I got Shreddit, made a config file (containing the necessary detail for all my accounts), and made a shell script that I ran three times a day, likely until June 30.

Nowadays, my accounts look clean enough, and whenever some post or comment resurface, the next run of the script should take care of it.

And just on top of all that, I do check my accounts from a different browser I never use Reddit on. So far it's clean-looking, no posts or replies showing on any of them. But whether or not Reddit actually deleted them, I'm not sure. I'm never sure.

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I had to DMCA some of my stuff off the site to get it to stay off.

Pardon my ignorance, but doesn't that just work for 30 days, until the review process for the DMCA is completed?

We'll see what they do. What I flagged I am the registered copyright holder for. Metallica proved that we can treat them stealing copyrighted material that was expressly forbidden like it's industrial espionage, I'm sure I can find an IP lawyer with a raging hate-on for Reddit.

Just use shreddit..

It apparently doesn't purge everything. I had used shreddit and I am still able to read some of my older comments. Luckily the actual posts are gone (I manually deleted everything).

Reddit is fishy either way - I was manually deleting my comments each day over the past week and occasionally reached the "end" of the comment list. "There seems to be nothing here" and "This user hasn't posted anything" displayed regardless of whether I used old.reddit or the redesign, and regardless of how I sorted the list (new VS top). A couple of hours later, there were comments again, multiple pages' worth of content....

After I got the "this user hasn't posted anything" message two days in a row, I used shreddit, and it found and deleted a whooping 981 MORE comments that reddit chose to not show me. And that was definitely not all of it, provable. (This comment for example is one of mine and I am rather sure that I had deleted it as I have the same text copy-pasted in my "saved from reddit before deleting" folder)

Oh that's real shady then. I'll go double check mine, I thought it was a one and done kind of deal.

I have been removing my posts from Reddit over the last week and have found that you don't see and can't remove posts from subreddits that you don't have access to. I keep seeing sets of posts all from the same subreddit as they come out of blackout.

This is the main reason people keep claiming comments are "being restored". They aren't, they just were on private subs that were reactivated.

But that means if you delete your account while a sub is private, you lose all access to be able to delete those posts when they come back.

Reddit needs to provide some kind of service or tool to delete ALL posts made by your account to avoid this problem. Many people who deleted their accounts without knowing this loophole are currently SOOL. I really, really hope they face some regulatory response/fines because of this.

I am obviously not a lawyer but I don't see how Reddit is in the wrong here. On GDPR.EU that "The EU’s GDPR only applies to personal data, which is any piece of information that relates to an identifiable person. It’s crucial for any business with EU consumers to understand this concept for GDPR compliance." I don't see how your comment history would be considered "personal data".

It even says in Reddit's TOS that "When Your Content is created with or submitted to the Services, you grant us a worldwide, royalty-free, perpetual, irrevocable, non-exclusive, transferable, and sublicensable license to use, copy, modify, adapt, prepare derivative works of, distribute, store, perform, and display Your Content and any name, username, voice, or likeness provided in connection with Your Content in all media formats and channels now known or later developed anywhere in the world".

You've agreed that your posts are no longer your "personal data" at that point...

I don’t see how your comment history would be considered “personal data”.

From the GDPR definitions: The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. In practice, these also include all data which are or can be assigned to a person in any kind of way. For example, the telephone, credit card or personnel number of a person, account data, number plate, appearance, customer number or address are all personal data.

irrevocable You’ve agreed that your posts are no longer your “personal data” at that point…

No, that is not how that works under European law at all. You can at **any **time revoke this right, that's one of the basic rules of GDPR. And yes, Reddit falls under GDPR as they specifically enable EU citizens to use their services.

And yes, Reddit falls under GDPR as they specifically enable EU citizens to use their services

And since they introduced their ambassador program where they tried to "clone" well know subreddits to make a local alternative (in German, French,...), they can't even deny it since they specifically targeted European countries

https://codepen.io/Deestan/full/gOQagRO/

Deletes all comments or swap them with anything eg "I've moved to Lemmy"

Doesn't seem to work.

First off browser didn't even allow to open embed website within none securely written website. With less secure setting old.reddit.com will refuse connection.

How to make it work?

Perhaps try a different browser. Worked fine for a couple of accounts in fire fox.

Firefox won't let me open it within that tool.
Edge and Chrome will allow me to open it but old.reddit.com refuses the connection. I guess they countered it or something ?

Yeah, I heard reddit stopped allowing it to delete posts, though mainly they've blocked it.

You tried moving the icon into the firefox bookmark toolbar then running it within reddit?

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