RGPD - Processing of personal data

From Ametys 4.9

  1. Unknown and inactive users
  2. Deleting personal data
  3. Tracing RGPD events

Unknown and inactive users

An unknown and inactive user is a user who has had an account, logged on to the application at least once and :

  • whose last connection date is greater than X months (X configurable)
  • which no longer exists in its user directory

From the administration interface, you can access the list of unknown users from the "Users > Unknown and inactive users" menu in the Users, groups and rights tab.

For each unknown user, the tool displays:

  • an icon representing the status of the data deletion process (in progress or not activated)
  • its name
  • his login
  • its home population 
  • date of last inactivity (date of last connection)
  • the date on which it was detected as unknown

This list is updated monthly, by a scheduled task, according to the application's general configuration settings, found in the Data retention policy > Inactive users status update category.
The parameters allow you to choose:

  • the day of the month and time of the list update
  • duration of inactivity in months, after which a user who no longer exists in his user directory will be added to the list of unknown and inactive users

Deleting personal data

For each unknown, inactive user, it is possible to initiate the personal data deletion process.

To do this, from the "Unknown users" tool, select one or more users and click on "Activate deletion process".

Personal data deletion is not immediate.
The data deletion process is carried out monthly, by a scheduled task, and applies only to unknown and inactive users whose personal data deletion process has been activated.
The time and day of the month at which the process will run can be configured in the general configuration settings in the Data retention policy > Delete personal data of unknown users category .

It is possible at any time to interrupt the deletion process for one or more users by clicking on "Suspend deletion process".

When the process is carried out, the deletion of personal data is only effective if the deletion policy concerning the data allows it.

Each type of data can have a different policy, governed by a configuration parameter.
In the Data retention policy > Retention period for personal data of unknown users (in months) category of the configuration parameters, you can define the retention period for each type of personal data.

The delay is expressed in months and runs from the date on which the user disappeared, i.e. the date on which the user was detected as unknown.
This delay can be empty to disable data deletion or equal to 0 to delete the data the next time the personal data deletion process is run.

For example, if "3" is set for user preferences, the preferences will be deleted after a delay of at least 3 months after the user's disappearance date.

The deletion of personal data may result in the deletion of the data or in anonymization.
Some examples:

  • user preferences are deleted
  • comments are anonymized
  • reactions (like) to content or comments are deleted
  • classified ads posted by unknown users are deleted
  • answers to forms are anonymized 

At the end of the process, as long as there is still personal data to be processed, the unknown user remains visible in the "Unknown and inactive users" tool.
When all data has been processed (deleted or anonymized), the user will be removed from the list.

Tracing RGPD events

Personal data deletion events are logged in the Forensic logs under the category "data.policy.gdpr".

Example of logs

2025-06-30 16:58:19,057 INFO [org.ametys.core.trace.ForensicLogger.data.policy.gdpr.anonymize.form.submissions] (AmetysRuntimeScheduler_Worker-5;) [127.0.0.1] [system-user#admin_population] data.policy.gdpr.anonymize.form.submissions (identity::UserIdentity [login=a.martin, population=ametys_demo_users]|handled::6) ()
2025-06-30 16:58:20,311 INFO [org.ametys.core.trace.ForensicLogger.data.policy.gdpr.remove.page.subscriptions] (AmetysRuntimeScheduler_Worker-5;) [127.0.0.1] [system-user#admin_population] data.policy.gdpr.remove.page.subscriptions (identity::UserIdentity [login=a.martin, population=ametys_demo_users]|handled::5) ()
2025-06-30 16:58:20,332 INFO [org.ametys.core.trace.ForensicLogger.data.policy.gdpr.remove.user.links] (AmetysRuntimeScheduler_Worker-5;) [127.0.0.1] [system-user#admin_population] data.policy.gdpr.remove.user.links (identity::UserIdentity [login=a.martin, population=ametys_demo_users]|handled::3) ()

In order, these logs allow us to trace the "a.martin" user in theametys population:

  • 6 responses to forms were anonymized
  • 5 subscriptions have been cancelled
  • 3 personal links have been removed
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