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traceroute66today at 2:45 PM1 replyview on HN

> even bad advice

That's putting it politely. Honestly, I think this "handbook" was mostly written by an LLM.

For example, in the immutability section we have this:

   "Separating PII from financial data lets you honor erasure without losing the financial history you’re obliged to keep."
In a financial organisation the two go hand-in-hand for obvious KYC/AML reasons.

Keeping the financial data whilst trashing the customer names, addresses etc. instantly on-demand before the expiry of the relevant time periods is going to leave your entire organisation with a very bad day in the office if a $lawful_body comes knocking for the data to trace a crime.

People going to work in a Fintech should not be relying on a random "Handbook" written by an unknown person in an unknown jurisdiction.

People going to work in a Fintech should only ever work in accordance with their employer's internal handbooks/guidelines/etc which will have been written in conjunction with their firm's lawyers and compliance people to ensure it complies with the laws and reporting requirements in the jurisdiction(s) in which their employer operates.


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lxgrtoday at 2:53 PM

> Keeping the financial data whilst trashing the customer names, addresses etc. instantly on-demand before the expiry of the relevant time periods [...]

Where does TFA recommend that?

As I see it, it recommends separating PII data you'll eventually have to delete from that you'd probably want to keep forever (including data factoring into your accounting equations/invariants), so that you can delete the former after the relevant recordkeeping periods have elapsed.

> People going to work in a Fintech should not be relying on a "Handbook" written by an unknown person in an unknown jurisdiction.

Sure, but they should also not blindly ignore any ideas and practices presented, or avoid looking beyond their own organization. Ideally, they'll then try to reconcile what they saw with their own knowledge and local regulations etc.

> People going to work in a Fintech should only ever work in accordance with their employer's internal handbooks/guidelines/etc which will have been written in conjunction with their firm's lawyers and compliance people to ensure it complies with the laws and reporting requirements in the jurisdiction(s) in which their employer operates.

Sure, in a world in with only perfect and error-free organizations, that seems like a reasonable approach. But how does one get there without having a conversation such as this one?

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