Removal Process of Client Personal Data from Fluent OMS/Ticketing System
Author:
Fluent Commerce
Changed on:
1 Dec 2023
Overview
This document describes Fluent Commerce's methodology to remove Personal Data submitted by or on behalf of a Client to the Fluent OMS and Fluent Commerce’s Ticketing System (Personal Data) from those systems.
Key points
- Fluent processes personal data related to two main categories of data subjects: the clients' customers who make online or in-store purchases and the clients' users of Fluent OMS, with the responsibility for data removal resting on the client/data controller.
- The processed personal data includes customer details, contact information, service preferences, and order history, stored in specific areas of Fluent OMS and the Support Ticketing System.
- The data removal process varies across different data stores, involving deletion or anonymization, and is subject to retention periods for backups and log data. Fluent ensures the removal of personal data from client requests in the Support Ticketing System as the final stage in the process.
Processed Personal Data
The Personal Data processed relates to the following categories of Data Subjects:
- The Client’s customers who have purchased goods online and/or through in-store physical channels;
- The Client’s users of the Fluent OMS to the extent that Fluent Commerce is considered a Data Processor to that data.
Removing Personal Data can be requested by the Client/Data Controller for a specific individual or in bulk at the end of the agreement. The Client is responsible for determining whether it has the right to make such a request under applicable privacy/data protection laws.
The Personal Data and the method for either Data Subject or request type remain similar.
The Personal Data processed by Fluent consists of the following categories:
- customer first name & last name;
- customer home & work addresses;
- contact email and telephone;
- contact & service preferences;
- digital identifiers & usernames;
- device & service usage history;
- order details & product items history; and
- order shipping & tracking history.
- Personal Data contained in custom attributes
This Personal data may only be stored in three areas of the Fluent OMS as well as the Fluent Support Ticketing System - as follows:
Fluent OMS - primary Order Management databases
The main Platform Databases are the “source of truth” for all the data classifications sent to Fluent by the client.
Fluent OMS - Event databases
The Fluent Platform stores Events as an audit trail or history of actions taken on the platform. While it is not recommended, users can store personal data in the event database as a secondary data store.
Fluent OMS - Platform Logs
Platform logs are captured to diagnose platform and support issues and can contain personal information within log messaging. Log data is read-only, encrypted (in transit and at rest), and restricted to a small subset of Fluent Employees.
Support Ticketing System
Requests for data removal would be raised to Fluent via the Support Ticketing System and contain the data subject's information to be removed.
The different data stores have different methods for removing data while still ensuring the consistency of the Client's data on the Platform.
Main Order Management databases
Customer Personal Data is only stored and linked to the orders the Customer places. All records and fields that contain Customer Personal Data are removed from the databases either by deleting the corresponding rows or non-reversible anonymisation if a reference is needed to maintain linking to corresponding order records.
After this process, the order remains to ensure the Client's data remains consistent, but Fluent no longer has any record of the end customer that placed the order. This includes names, addresses, contact details, customer ID, or reference numbers.
Fluent requires only minimal Personal Data on the Client's users of the Platform. The client user record is removed to remove these data subjects, and their previous activity is linked to a “deleted user” record.
Automatic Database backups are taken daily but only retained for 7 days. Once data has been removed from the database, that data would no longer be available in back-ups after 7 days.
Event databases
Events linked to an order placed by the Customer have two types of attributes:
- Fluent-related metadata
- Custom attributes implemented by the Client or Implementation Partner
Fluent Commerce requires Clients to agree with Fluent Commerce additional data that it wishes to capture/store using custom attributes before storing such data in custom event attributes. Fluent Commerce can remove data per this agreement. Without this guidance from the Client, Fluent removes all Custom attributes from all events related to Data Subject Customer orders.
This ensures that audit Events remain with basic order-related metadata, such as timestamps when order statuses change, but no customer Personal Data.
Automatic Database backups are taken daily but only retained for 7 days. Once data has been removed from the database, that data would no longer be available in back-ups after 7 days.
Platform Logs
Log data life-cycle is configured to 3 months, upon which the data is no longer available once 3 months is exceeded. If data contains personal information that needs to be removed earlier, the log stream containing that data is deleted. Removal of this data reduces Fluent's ability to support issues raised against this order but does not otherwise impact the Platform or the Client data
Support Ticketing System
The final stage is removing Personal Data from any Client request raised in the Fluent Support Ticketing System. This includes the request raised to remove the data subject.
