GDPR - Removing Personal Data from Surveys

Important- this article does not constitute legal advice. You should ensure that you are aware of your responsibilities regarding personal data at all times while using SmartSurvey.

One of the obligations placed on data controllers under GDPR is that personal data is not held for longer than is necessary to perform the task for which it was collected. This guide relates to removing personal data in bulk from existing surveys. For removing individual responses under the "right to erasure", see GDPR – Complying with requests from respondents.

GDPR defines two classes of entities for handling data - Data Controllers, and Data Processors. SmartSurvey is the Data Controller for the data it holds about users. It is the Data Processor for the data collected about respondents by users. Users are the Data Controllers for the data about respondents collected by users.

How long data should be kept will vary from user to user and from survey to survey, but an important thing to note is that this restriction applies only to personal data. Many surveys will contain a mixture of personal and non-personal data, depending on the question being asked, and while the personal data should be removed after an appropriate amount of time, the non-personal data can be kept.

We have identified three differing situations regarding this, listed below along with the actions to take:

Case 1: Where personal data has been explicitly asked for as a survey question.

The current process will be to export the survey, delete the personal data from the export, then delete or clear the survey.

Case 2: You have a question in your survey that warrants a typed response (such as a text or comment box).

Because a respondent may have answered with Personal Data. In this case, you will have to manually review those responses to determine whether action needs to be taken, and if so, manually edit the response to remove the Personal Data in question. Please contact us on 0800 0937 822 if you wish to contract SmartSurvey for this task.

Case 3: Where a survey has been sent using an email or SMS collector, and the survey was not set to be anonymous when created.

it is currently not possible to delete respondent contact data email addresses, IP addresses, or SMS numbers from the survey responses. In this case, the whole survey should be deleted (or all responses cleared, if the survey will be used again). If there’s data you wish to preserve, export the data prior to deletion or clearing, then delete the personal data from the export file, and save it.

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