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GDPR data deletion request

Viktoriia Golovtseva

November 3, 2025

GDPR Data Deletion Request Template

Atlassian, Jira Information Security Smart Checklist Smart Templates Templates

Getting a data deletion request right is a core part of GDPR compliance. Under GDPR Article 17, a data subject can ask you to erase their personal data. This “right to be forgotten” applies to many modern services, including information society services, social media accounts, and SaaS tools you run for customers or employees. If you serve users in the European Union, you must process such erasure requests without undue delay. Most cases require a response within  1 month.

Why this matters: GDPR reshaped how teams handle data privacy. It introduced clear user GDPR rights, stricter consent rules, and real penalties for non-compliance. Even companies outside the EU fall under general data protection regulation if they process EU residents’ data. The safest approach is to build a predictable workflow you can run every time a deletion request arrives.

In this article, we’ll show a reusable GDPR compliance template you can run inside Jira with Smart Checklist and Smart Template tools by TitanApps. You’ll learn when you must delete data, when you can refuse based on legal obligation, public interest, public health, or legal claims, and how to handle edge cases like legitimate interest. We’ll also share practical tips from our Information Security team on consent, retention, and record-keeping to keep your privacy requests consistent and auditable.

What you’ll get:

  • A clear request template and request form structure to capture identifiers like full name, email, telephone number, or LinkedIn profile URL, so you can locate data across systems.
  • A step-by-step ticket workflow in Jira to triage, verify identity, assess legal basis, and complete data removal or refusal with a documented follow up.
  • Practical guidance on consent logs, data minimization, data retention rules, and coordination with your Data Protection Officer.

Before we dive in, one mindset shift: collect only what you need, store it only where you must, and know exactly who can access it. Smaller footprints make GDPR work simpler and safer. Our security lead calls this the “golden rule” of privacy operations.

What a GDPR data deletion request covers 

A data deletion request, also called an erasure request or the right to be forgotten, comes from a data subject who asks you to remove their personal data under GDPR Article 17. You must act without undue delay and usually within 1 month. If you need more time, you should explain why and keep the requester informed.

You can erase when data is no longer needed, consent was withdrawn, or your legitimate interest no longer outweighs the person’s privacy. Your privacy notice and consent logs should make these decisions traceable. Keep an audit trail for every step.

You may refuse deletion when the data must be kept to meet a legal obligation, support legal claims, serve a public interest (e.g., public health), or meet specific financial record-keeping rules. In those cases, document the legal basis and tell the requester what stays and why.

Appoint a Data Protection Officer when required. The DPO should sit close to leadership and coordinate your GDPR compliance program, including deletion workflows, vendor checks, and data minimization. Less data means less risk and fewer deletion edge cases.

Mind your processors and sub-processors. If your product runs on a cloud platform (for example, a hosting provider), list those vendors, know where data is stored, and make sure your Data Processing Agreements cover data removal across systems.

Finally, build deletion into the lifecycle: clear retention periods, consent records, and an easy way for users to unsubscribe or request removal from a webpage or request form (email to legal is acceptable, but it must be easy to find). These basics keep you on track for Article 17 and help your team respond on time.

Step-by-step: handle a GDPR data deletion request (Art. 17)

Below is a practical workflow you can run in Jira (or any service desk) to process a data deletion request from a data subject. It maps to GDPR Article 17 (“right to erasure / right to be forgotten”) and keeps your GDPR compliance docs tidy.

Step 1: Intake

Accept requests through a simple request form or a dedicated inbox (e.g., privacy@). Capture the requester’s full name, email/phone number, account ID, and a short description (“erasure request”). Log the ticket in your ticket management system for follow up.

Step 2: Verify identity

Confirm you are dealing with the correct person. Ask for reasonable proof tied to the account (no credit card scans). Record checks in the ticket. Request only necessary identity data. Delete or redact verification artifacts after checks unless law requires limited retention.

Step 3 : Confirm scope and systems

Locate all personal data across your products, backups, and vendors. Use your data inventory: what you collect, where it’s stored, who can access it, and for how long. Include any sub-processors (e.g., cloud hosting) listed in your DPA page.

Step 4: Check lawful basis and valid exceptions

Erasure is required unless you must keep data for a legal obligation, public interest, public health, or legal claims. Contract records or financial logs may need retention. Document the decision and explain it to the requester.

Step 5: Decide on deletion vs. anonymization

Remove or anonymize data that is no longer needed under your retention policy. Apply data minimization: do not keep what you do not use.

Step 6: Execute across systems and vendors

Remove data in your app, data lake, analytics, social media integrations, and information society services you use. Notify each processor to delete matching records and confirm completion. Track confirmations inside the ticket.

Step 7: Meet the deadline

Respond without undue delay and within 1 month. If you need more time, tell the person why and when to expect completion. Keep the timeline visible to your Data Protection Officer and legal.

Step 8: Close the loop

Send a clear confirmation of data removal. If you must keep some fields, explain the legitimate interest or legal obligation and when those records will expire. Offer a simple unsubscribe path for marketing. There is also a recommendation to add the requester to a suppression (‘do not contact’) list so marketing systems don’t re-add them.

Step 9: Update records and policy

Log what you deleted, systems touched, and dates. Keep your retention schedule and knowledge base current. Train team members and schedule refreshers annually; the DPO oversees the program.

Tip: build this as a Smart Checklist inside your GDPR compliance template. Add mandatory items for identity verification, legal basis review, vendor calls, and final confirmation. This makes service level tracking easy and keeps every deletion request consistent with GDPR data protection law and your internal SOPs.

Bring it together: a reusable GDPR Compliance Template for Jira

Your data deletion request checklist sits inside a broader GDPR program template. Think of it as one playbook that covers day-to-day privacy work (consent, notices, retention) and operational requests (access, correction, right to erasure).

What is the GDPR Compliance Template?

A structured set of Jira issues and checklists that map to core General Data Protection Regulation duties: documenting personal data, choosing a lawful basis, handling data subject requests, managing vendors, and proving your process on audit. It keeps every erasure request consistent and traceable, while your Data Protection Officer can monitor status and deadlines.

Why build it in Jira with Smart Tools?

Jira gives you tracking, ownership, and timelines. Smart Checklist adds clear, testable steps to each task so nothing slips. Smart Templates let you spin up the same structure per quarter, per product, or per region. That combination streamlines privacy work without extra spreadsheets.

How to create a customizable GDPR compliance template in Jira

1. Design the template structure
Create a parent “GDPR Compliance” epic, then child issues for the main areas below. Attach Smart Checklists to each issue.Add variables for reuse

2. Use variables wherever details change by region or product:

    • {{controller_name}}, {{dpo_name}}, {{dpo_contact}}
    • {{product_name}}, {{processing_activity}}, {{region}}
    • For requests: {{request_id}}, {{data_subject_name}}, {{request_received_date}}

    3. Automate the workflow

      • Auto-create the full template on a schedule (e.g., quarterly reviews) or on “New Privacy Program” trigger.
      • For data deletion requests, auto-create a “Privacy Request” issue with your Erasure checklist when the mailbox or portal receives a new ticket.
      • Add validators so an issue cannot move to “Done” until mandatory privacy checks pass.

      Use this structure in the Smart Template as the baseline for your program. Define the structure, then tailor issue names, owners, and due dates with variables.

      Do not copy the template structure below, use it as a guidance.

      ## Map & Document Personal Data

      - List all personal data you collect & process

      - Record storage locations & access permissions

      ## Verify Legal Basis for Processing

      - Confirm lawful basis (consent, contract, legitimate interest…)

      - Document decisions for audit trail

      ## Review & Update Privacy Notice

      - Make it clear, friendly & accessible

      - Include purpose, legal basis & user rights

      ## Set Up Data Subject Request Process

      - Create workflow for access/correction/deletion requests

      - Ensure responses within 30 days

      ## Implement Consent Management

      - Capture & store proof of consent

      - Provide easy way for users to withdraw consent

      ## Apply Data Minimization

      - Collect only what’s strictly necessary

      - Review & delete unused data regularly

      ## Define Data Retention Policy
      - Set retention periods for each data type

      - Schedule clean-ups or anonymization

      ## Strengthen Security Measures

      - Apply encryption, access controls & monitoring

      - Review & document risk assessments

      ## Run DPIAs (Data Protection Impact Assessments)

      - Identify high-risk processing activities

      - Record mitigation steps

      ## Manage Third-Party Processors

      - Sign Data Processing Agreements (DPAs)

      - Verify vendors’ GDPR compliance regularly

      ## Check International Data Transfers

      - Confirm where data leaves EU/EEA

      - Use proper transfer mechanisms (SCCs, adequacy decisions)

      ## Prepare for Data Breaches

      - Maintain incident response plan

      - Notify authorities & users within 72h if required

      ## Train Employees

      - Provide GDPR & privacy training

      - Track completion & schedule refreshers

      ## Monitor & Audit Regularly
      - Audit data processing records periodically

      - Keep documentation up to date

      ##  Appoint DPO (if required)

      - Assign a Data Protection Officer

      -  Publish DPO contact info for users & regulators

      Where the Data Deletion Request checklist fits

      Place your “GDPR Art. 17 – Data Deletion Request” checklist under the “Set Up Data Subject Request Process” issue. Mark identity verification, lawful-basis review, vendor notifications, and final confirmation as mandatory items. Add SLA fields to track the 1 month timeline and escalate if a due date is at risk. 

      Example:

      Epic: GDPR Compliance Program — {{region}} — {{quarter}}

      • Issue: Map & Document Personal Data — {{product_name}}
      • Issue: Legal Basis Review — {{processing_activity}}
      • Issue: Privacy Notice Refresh — {{region}}
      • Issue: Data Subject Requests — Process & SLAs

      Smart Checklist: GDPR Art. 17 — Data Deletion Request steps

      • Issue: DPIA — {{processing_activity}}
      • Issue: Vendor Reviews & DPAs — {{vendor_name}}
      • Issue: Intl Transfers — {{destination_country}}
      • Issue: Breach Readiness Drill — {{date}}
      • Issue: Training & Awareness — {{department}}
      • Issue: Quarterly Audit & Evidence Pack — {{quarter}}

      Pro tips from our privacy review playbook

      • Keep a single privacy request queue. Use components or labels for “access,” “rectification,” and “erasure.”
      • Store proof of consent and legal basis decisions as attachments or checklists so you have an audit trail.
      • Add an automation rule to remind owners 7 days before the erasure SLA.
      • Record what was deleted, where, and which third-party processors confirmed completion. This becomes your evidence pack for auditors and for the DPO.

      Make it work day to day: roles, SLAs, and audit evidence

      We recommend assigning clear owners for each privacy task in Jira. The Data Protection Officer (DPO) oversees the program. A privacy analyst or legal reviewer validates lawful basis and exceptions. IT executes deletion across systems and third-party processors. Customer support handles the data subject follow up.

      Track SLAs inside Jira. Set a 30-day timer on every data deletion request and add an escalation path at 20 and 27 days. Use labels for right to erasure, access, and rectification so your queue stays searchable.

      Keep an evidence pack. Attach proof of identity checks, lawful basis review, erasure confirmations from vendors, and the final reply. This supports GDPR compliance and speeds audits.

      Where Smart Tools help:

      • Smart Checklist: turns Article 17 steps into testable items with mandatory checks.
      • Smart Templates: spins up the same structure for each erasure request and each quarterly review.
      • Jira automation: routes work to the right team, reminds owners, and blocks “Done” until mandatory steps finish.

      Wrapping up

      A reliable GDPR data deletion request process protects users and your business. Build it once as a reusable template in Jira, attach the GDPR Compliance Checklist, and enforce service level agreements with automation. Your team gains clear roles, faster response times, and a full audit trail. Users get timely answers on their right to be forgotten. That is real GDPR compliance in action.

      If you want help turning this into a ready-to-use workflow, we can package the template, checklists, and automations for your product, region, and third-party stack.

      FAQ: GDPR Data Deletion Requests (Right to Erasure)

      What is a GDPR data deletion request?

      It is a data subject request to remove personal data under the right to erasure (“right to be forgotten”). You must verify identity, check lawful basis, process erasure across systems and vendors, and respond without undue delay.

      How fast must we respond?
      You should reply within 1 month. Use Jira SLAs to track the deadline, send real-time reminders, and escalate when due dates approach.

      When can we refuse an erasure request?
      The General Data Protection Regulation allows exceptions. You may keep data for legal obligations, public interest, public health, historical research, or legal claims. Document the decision and inform the user. You can check all the exceptions in the Article 17.3 of GDPR 

      What personal data falls under erasure?
      Anything that identifies a person: full name, email, telephone number, credit card token, social media handle, LinkedIn URL, IP, device ID, and more. Include copies in backups and vendor systems when feasible.

      How do we prove GDPR compliance?
      Maintain a full audit trail in Jira: request intake, ID check, ticket categorization, lawful-basis review, actions taken, vendor confirmations, and the final response. Link artifacts to your DPO issue.

      How do we handle third-party processors?
      List all processors in your records. Send erasure notices under your DPA terms, track confirmations, and add them to the evidence pack. Verify their GDPR compliance during vendor reviews.

      Can we automate parts of the process?
      Yes. Use Jira automation to assign tickets to the appropriate team, set ticket priority, and enforce validators so issues cannot close until all checklist items pass. AI-powered routing can help classify support requests by type.

      What should our deletion workflow include?
      Identity verification, scope of systems, ticket triage process (category, priority), action steps for production data, logs, caches, and backups (as feasible), processor notifications, follow-up to the user, and post-mortem metrics on resolution and timing.

      How do we integrate with our help desk or service desk?
      Create a service desk intake form for privacy requests. Map those to a Jira project with your template. Route incoming tickets to legal or privacy, and push work to IT support for execution.

      What about non-EU requests (e.g., CCPA)?
      Keep a parallel workflow for privacy requests under CCPA and other data protection law. Reuse the same structure with a different request template and response language.

      How do we handle backups and downtime windows?
      Document what is technically possible. If immediate purge from backups is not feasible, mark for expiry on restore. Schedule steps to avoid downtime on production systems.

      What metrics should we track?
      Volume of erasure requests, average and median response times, SLA breaches, processor turnaround, and re-opened cases. Use Jira dashboards to monitor trends and optimize the workflow.