That is not quite correct. As long as it is possible to identify the user, it is personal data. True anonymization under GDPR is nearly impossible without destroying the data set.
Reddit would have to fully delete it, otherwise simply searching Google with the exact text with site:reddit.com on any comment immediately reveals who the author is.
It doesn't matter if the dataset in use allows for identification, as long as identification remains possible.
The DPAs have discretion on how they interpret the laws and what guidance they give. This is something you could only really pursue through litigation beyond what reply you're getting from your DPA. Personally, I am not trusting reddit to actually, truly delete anything. But there would need to be proof for that, beyond my suspicions.
If deleted was truly deleted, I'd say they're right on an individual case.
The issue I'm outlining is however of a different nature, so I am somewhat hopeful at least some DPA will take this issue on.
Every post is tied to a username and email address, making it personal information, since each poster can be identified. I'm sure they're also tracking further metrics such as IP addresses, browser fingerprints, etc. It is immaterial if we from the outside are able to identify users, it only matters if it's possible given the data available to the processor. In this case, it is. Not to mention, there is a good chance texts and posts themselves contain plenty of personal information, such as linking to other user profiles, mentioning and discussing people, etc.
As I've already stated in reply to a comment of yours on the other crosspost, no. I am a certified data protection officer and you do not need to be a lawyer to have some competence in dealing with the GDPR. The GDPR specifically outlines the role and required qualifications for the data protection officer.
DPOs in Europe don't always work with lawyers. I mainly deal with mid-sized companies and work with lawyers on the end of the larger corporations, absolutely. I was simply clarifying I am not a lawyer and don't claim to be one.
The requests don't go to reddit, but the supervisory authorities. They can try and ignore those requests, but since they have offices in the EU, those can and will be slapped around - if any DPA takes action, that is.
Potentially several, I've outlined it in the post linked here. https://kbin.social/m/reddit@lemmy.world/t/854162/Any-EU-based-users-of-reddit-should-immediately-file-a
It's outlined in my post, you can of course continue to ignore it. That's fine.
Awesome, thank you!
Nope, your username and email are required and linked to your data, so it's entirely personal information. True anonymization is impossible with open text fields, as it's always possible that people reference other users within their posts, etc.
Of course, what the DPAs do with it, is another matter. Doesn't hurt to try.
I'm not a lawyer, but a data protection officer with certification in Germany.
It doesn't matter, as long as the text is supplied as is, a simple Google search with the text and site:reddit.com will reveal the author, keeping it identifiable. True anonymization under GDPR almost does not exist, as it would destroy the dataset and make it unusable.