Block banned & deleted members

[jamesgeddes]

Hypothetical scenario:

1. GZ/Trustees ban a member from GZ
2. Former member issues GDPR article 17 request.
3. GZ deletes all personal details
4. Former member creates new account using the same details as previously provided

In this scenario, GZ has no systematic way to differentiate new members from banned and deleted members.

How do we address this?

This will likely need to be split into several smaller tickets.

Impact

High

Urgency

Later

[jamesgeddes]

Hannah Baller (GZ Trustee) has contacted the Information Commissioners Office and has confirmed that those who are removed from membership by the GZ/Trustees do not have a right to erasure under the GDPR;

The right to erasure does not apply if processing is necessary for one of the following reasons:

• to comply with a legal obligation;
• for the performance of a task carried out in the public interest or in the exercise of official authority;

A member who is in good standing does have the right to erasure, which can be automatically actioned. The member should be encouraged to discuss this action with the Trustees before they proceed. This members (now anonymised) record would then be marked as "Resigned", as they elected to leave.

In this scenario, however, a member who has been "Suspended" or "Removed" does not have the right to delete their account. This is because the GZ/Trustees must carry out their legal obligations and exercise their official authority to prevent such individuals from being readmitted to membership.

A Trustee must, therefore, be able to mark a member as,

• "Suspended", with a reason and a time limit. Trustees should be reminded that this will be visible to the member.
• "Removed", with a reason

This must require approval from at least one other Trustee so that this can be recorded in the audit log.

Once a member is marked as "Suspended" or "Removed", they are to be,

• locked out of their account
• shown the type of lockout; "Suspended" or "Removed"
• shown the reason provided by the Trustees.
• shown the date that the action concludes; datetime or "Permanently"
• suspended from payment collections
• removed from any physical access they might have to Geek.Zone facilities

Any attempt to join Geek.Zone with personal information that matches those found in the Suspended or Removed accounts are to be blocked.

Again, this is much more work than should be crammed into one ticket, so should be split as required. I only want to ensure that I document the requirements.

[jamesgeddes]

I would also like to note that I hope we never have to use this feature, however, it is required just in case we do need to do so.