How to leave Facebook - followup 1

The electrons were barely dry on my last post when I received an email from TRUSTe about the problems I'd had getting Facebook to close my account; the interesting bit is below:

Thank you for submitting your privacy complaint through the TRUSTe Watchdog Dispute Resolution program. The TRUSTe Compliance Team has reviewed the details of your complaint and we have determined that it is a valid privacy complaint. We have contacted www.facebook.com on your behalf and have outlined the steps necessary for proper resolution.

So my advice to you if you are having problems getting Facebook to close your account is to submit a complaint to TRUSTe.

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How to leave Facebook

As I documented in my last post, it isn't actually possible to leave Facebook, all you can do is 'deactivate' your account. I got in touch with Facebook and asked them to delete my account, and here is the reply I got from them:

If you deactivate, your account is removed from the site. However, we save all your profile content (friends, photos, interests, etc.), so if you want to reactivate sometime, your account will look just the way it did when you deactivated. If you do want your information completely wiped from our servers, we can do this for you. However, you need to remove all profile content before we can do this. Once you have cleared your account, let us know and we'll take care of the rest.

I wrote back to Facebook, saying that their response was unacceptable. I noted that their Privacy Policy page says that they are a licensee of the TRUSTe organisation, and that as such they are supposed to give users "choice and consent over how their information is used and shared". I also pointed out that as they are now registered in the UK, they are probably also subject to UK data protection legislation. Finally, I pointed out that Facebook had also been mentioned in a Channel 4 news report about identity theft, and that the media were obviously interested in Facebook's stance on data privacy and protection. I explained that if Facebook wasn't prepared to close my account I was prepared to take up the issue with the three avenues open to me, the TRUSTe complaints process, the UK Information Commissioner's Office (ICO) and the UK press.

In return I got exactly the same response as the one above. I wrote back to Facebook yet again, repeating that that their response was unacceptable, and that I was therefore going to take the three courses of action I outlined above. I registered complaints at both TRUSTe, the ICO and I also emailed Channel 4 News, explaining my story.

Last week Channel 4 came to interview me, and the item went out on Channel 4 News on Saturday 17th November. A video of the item can be found on the Channel 4 website. There's also details of the response from Facebook to C4's questions about their policy and process for account closures. Once the item had aired, I wrote again to Facebook, explaining that their response was still unacceptable, and that I'd taken the three options I'd identified in my earlier mail. Here's an excerpt from my mail to Facebook:

The Channel 4 web page I refer to above says:

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Vanessa Barnett, an internet lawyer with Berwin Leighton Paisner, told Channel 4 News: "The Data Protection Act is designed to protect individuals like me from having our data used in ways that we don't want. We get to choose how data gets processed, what people can do with it, and if we don't like it, we can say, 'Please stop'"

"Ultimately it's a question for the information commissioner as to whether someone is in breach of the act. And he has to balance two different things. Yes certainly, I as an individual have the right to say, 'please don't have my data,' but he also has to balance the rights of the business not to have to expend lots of money trying to get rid of that data."

So could Facebook argue that it's just impossible for them to provide an easier way to delete data? Or that they don't have the money to implement one? They didn't make that claim to us. In fact, they didn't engage with the question of why they need to retain data at all - they just didn't answer it.

Vanessa Barnett again: "One of the very key things that the information commissioner will look at is the resources of the business. And if that business has lots of money and lots of IT infrastructure, has the capabilities for example to easily write scripts to delete it, that will certainly sway the information commissioner into whether that data should have been deleted."
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I also notice that Facebook make the following statement on their Privacy Policy page:

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In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at XXXXXXXX.
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So it seems quite clear that Facebook *does* have the ability to delete accounts from the system, but for some reason chooses not to, other than for children of under 13. I will be pointing this out to the UK Information Commissioner.

Once again, I reiterate my case - Facebook has a duty to make it possible for users to delete their accounts in a reasonable and convenient manner, and from the statement on the Facebook Privacy page, Facebook clearly already has the mechanisms in place to make this possible.

I await your response with interest.

As well as sending my mail to the Facebook support person I had been dealing with, I also sent it to Chris Kelly, Facebook's Chief Privacy Officer, and Mark Zuckerberg, the Facebook CEO. Neither mail bounced, so I must have guessed their email addresses correctly. Earlier on today I received the following response from Facebook:

We have permanently deleted your account per your request. We do not retain any information about your account once it is deleted, and thus deletion is irreversible. Please let me know if you have any other questions or concerns.

Hurrah! Although to be honest, this raises almost as many questions as it answers. If Facebook has the ability to delete accounts so easily, why don't they make it available to users? In their written response to C4 they say that "Facebook does not use any information from deactivated accounts for advertising purposes." If that is the case, why do they retain the information at all? And although they aren't using it for "advertising purposes", are they making other use of it, and if so, what?

I'm still waiting for responses from either TRUSTe or the ICO, I'll be sure to blog about them when I receive them. In the meantime, if you want to get Facebook to delete your account entirely, you can always try mailing them, quoting the clear precedent they have set by closing my account. I really can't understand why Facebook make the whole process so difficult, they are an extremely popular service and the amount of work involved in closing accounts properly is tiny in comparison to the volume of activity the site sees.

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