TenthFleet:GDPR
This page explains how the Tenth Fleet wiki handles personal data in its historical record. It is a statement of our record-keeping policy, not legal advice.
Data Protection and the Historical Record is the policy governing how personal information is kept, redacted, or restored in the Tenth Fleet wiki, which serves as an indexed archive of orders, directives, awards, and unit histories for The Royal Manticoran Navy: The Official Honor Harrington Fan Association.
Our commitment
We respect the data-protection rights of every member. This includes the rights granted under the European Union's General Data Protection Regulation (GDPR), the equivalent United Kingdom regime (the UK GDPR together with the Data Protection Act 2018), and comparable laws elsewhere. Where a member asks us to correct or remove their personal data, we take that request seriously and act on it.
At the same time, TRMN keeps an accurate historical record in the public interest. Our orders and directives are the primary source used for command lineage, unit histories, promotion and award records, and training examinations. That record only works if it is complete and faithful to what was actually issued. Data-protection law recognizes this kind of tension directly, and provides for it. This policy explains how we balance the two.
The right to erasure, and why it is not absolute
Under Article 17(1) of the GDPR, a person generally has the right to erasure (sometimes called the "right to be forgotten"): the right to ask an organization to delete personal data it holds about them.
That right is not unlimited. Article 17(3) lists situations where it does not apply. The one that matters for an archive like ours is Article 17(3)(d), which removes the erasure right to the extent that keeping the data is necessary:
- "for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) ... in so far as the [erasure right] is likely to render impossible or seriously impair the achievement of the objectives of that processing."
In plain terms: if deleting a name would break a genuine historical record that is kept for the public good, the law lets the record stand. Article 89(1) is the companion rule that requires such archives to be handled responsibly, keeping only what the record actually needs and nothing more.
Why this exemption exists
The purpose of the archiving exemption is to stop the right to erasure from quietly erasing history. Public registries, museum catalogs, muster rolls, and official orders are all records where the identity of the people involved is part of the fact being recorded. If a ship's commissioning order could later have the commanding officer's name struck out, the order would no longer be a truthful record of who commanded that ship. The exemption keeps the archive honest while still limiting how that data may be used: it may be kept and consulted as history, but not repurposed to make decisions about the individual or to build a profile of them.
That is exactly how we treat it here. A member's name appears in our archive only as it appears in the official record of their appointments, commands, promotions, and awards. We do not expand those entries into personal biographies (see also our practice that this is not a biographical site), and we do not use the record to make any judgment about a living person.
The United Kingdom position
Because much of the Honorverse fandom and TRMN's own framing is British, members sometimes ask whether the United Kingdom keeps the same exemption after leaving the EU. It does.
- The UK retained the GDPR as domestic law (the UK GDPR). Article 17(3)(d) survives in the same words, so the archiving and historical-research exemption to the right to erasure applies in the UK just as it does in the EU.
- The Data Protection Act 2018, section 19 sets the UK safeguards for this kind of processing (the Article 89 conditions). Importantly, section 19 says the exemption is not available where the processing is likely to cause substantial damage or substantial distress to a person, or where it is used to make measures or decisions about a particular individual. An archive of historical orders does neither.
- The Data Protection Act 2018, Schedule 2, paragraph 28 separately sets aside several other data-subject rights (such as access, rectification, restriction, portability, and objection) for personal data processed for archiving in the public interest.
So under both the EU and UK regimes, a faithful public-interest archive may retain names that appear in its official records, subject to handling the data responsibly and never in a way that harms the individual.
Children's personal data is always redacted
There is one line we do not cross, regardless of the exemption above: we do not publish the personal data of children.
Data-protection law gives children's data special protection (GDPR Recital 38 notes that children "merit specific protection"), and the UK safeguard against causing "substantial distress" weighs even more heavily for a minor. Where a name in an order belongs to a child member, identifiable by a youth rank such as Cadet Ranger, that name remains redacted even though the surrounding order is preserved as historical record. The command or crew entry is kept; the child's name is not.
How this looks on the wiki
- Orders and directives are preserved as issued. Where a name was previously removed and has been restored under the historical-record exemption, or is deliberately withheld, the entry carries a short note linking back to this policy.
- Restored entries are the names of adult members as they appear in an official appointment, command, promotion, or award.
- Withheld entries are children's names, and any data still subject to an active erasure decision that the exemption does not cover.
- We honor erasure and correction requests except to the extent the archiving exemption applies, and children's data is redacted in every case.
Making a request
A member who wishes to correct or remove their personal data, or who has a question about how their data appears in the record, should contact the wiki administrators or the appropriate TRMN officer. We will review each request individually and apply this policy in good faith.
References and sources
- GDPR Article 17 (Right to erasure), gdpr-info.eu
- GDPR Article 89 (Safeguards for archiving and research), gdpr-info.eu
- Right to erasure, UK Information Commissioner's Office
- Data Protection Act 2018, section 19, legislation.gov.uk
- Data Protection Act 2018, Schedule 2, Part 6 (Archiving in the public interest), legislation.gov.uk