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Our customers would love to have GDPR-compliant contact management on their Marketing Cloud. We have enabled Contact Deletion on the account via Contact Builder's Contact Configuration. The deleted contacts are reportedly quarantined in a suppression list for a determined amount of time before they are completely deleted.

But we would like to know what happens if a new contact with the same ContactKey or the same Email re-enters the account via a scheduled import? And if this creates a new contact to which we will continue to communicate (despite the recipient's will), what is the best way of having a comprehensive GDPR-compliant strategy in place?

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    Yes, if you delete someone completely, they can enter again if they synch from another system. If you want to be compliant with GDPR, you need to delete all info about a person, so you cannot store info about them that you would use to prevent them from receiving further emails.
    – zuzannamj
    Aug 27, 2019 at 12:26
  • but how do we ensure that the people do not re-enter the external system? Of course, this depends on how do they manage their contact data. But as you mentioned, Marketing Cloud has no way of recognising a contact that has asked to be anonymised. Am I right? Aug 27, 2019 at 12:51
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    yes, you then need to make sure they disappear from the external system as well. and if they reenter, it means that they actually opted-in again and want the communications.
    – zuzannamj
    Aug 27, 2019 at 12:55
  • thank you for your help! Aug 27, 2019 at 13:30
  • How can the contact re-enter the system? By the contact person themselves or by buying stock contacts on the black market? Aug 27, 2019 at 20:12

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You would need to remove their address/contactkey from your system as well to stay GDPR compliant. The Marketing Cloud will allow the contact key back into the system after it has been fully deleted. This includes having the device register to the Marketing Cloud from the SDK.

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  • So, in case the same contact re-enters the system when they had been previously anonymized and deleted, Marketing Cloud has no way of knowing that? Aug 27, 2019 at 12:50
  • Correct. Deleted means deleted without a trace.
    – Bill Mote
    Aug 27, 2019 at 12:50
  • It's recommended to export the contacts before deleting them.. Aug 27, 2019 at 14:11

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