GDPR Compliant - Subjects of Erasure

This is a how-to guide for customers of VitalSource who are integrated with us via our Fulfillment APIs and are in receipt of a Subjects of Erasure Request (SAR.)

As a reminder, SAR requests require the data controller (the owner of the customer) and the data processor (VitalSource) to remove or erase all data related to the "subject."

This can be achieved in a fully automated fashion via the VitalSource fulfillment APIs if the following criteria are met:

1. The user account at VitalSource was created directly over our APIs using your API key.
   • This is often, but not always, a "reference" user account.
   • Full user accounts can also be deleted
2. You have access to the GUID or Reference ID associated with the account
3. You have saved/stored all content creation codes associated with this account

AS A POINT OF CONFIRMATION THIS PROCESS IS IRRETRIEVABLE. THIS IS THE DIGITAL EQUIVALENT OF DESTROYING BOOKS YOU HAVE PURCHASED. THE ONLY WAY TO "RE-CREATE" THE ACCOUNT AFTER THESE STEPS WILL BE FOR THE USER TO RE-PURCHASE ALL CONTENT.

Before you begin this workflow, it is our recommendation (and current practice) that you gain explicit confirmation from the user that this action will immediately and irrevocably remove access to any content licensed to their account.

N.B. The VitalSource refund policy will still apply. Content refunds will be process automatically, only if BOTH of the following criteria are met:

• The user has read LESS than 20% of the book
• LESS than 14 days have passed since the code was redeemed
  • You can validate this prior to processing the DELETE request, based upon your records.

If a refund is valid on any of the content, VitalSource will return the funds via the same channel we were originally paid. I.e. As this is an integration, VitalSource will place a credit on your next billing cycle.

Integration Difficulty: Basic

Integration Steps to Complete:

1. DELETE v4/codes endpoint:

• In a loop, send all previously granted codes (associated with this account) as DELETE requests to v4/codes. This will remove all content from the account immediately in all online instances, and at next contact with the internet with installed Apps.

2. PUT v3/users endpoint:

• Working with the Update user endpoint with either the GUID or reference ID as your parameter you will now OVERWRITE every identifier field previously used for this account with random characters.

  • First, Last & Affiliate are common for reference users
  • Email is the additional field on a full user account
    • Make sure to format as "ABCD@EFGH.COM"

State of the account:

• The user account is now empty of content
• The account is now anonymized
• The account is associated only with your API key
• Even in the case of a full-user account the account is inaccessible as you have changed the email address to random characters
• If the user has installed App(s) that are already signed-in, content will disappear as soon as they make connection to the internet.

Final Step:

• Abandon the account by deleting the GUID or reference ID on your side