Users can delete their account and PII is actually purged

GDPR Art. 17 ("right to be forgotten") and CCPA §1798.105 both require that a user who asks for their account and personal data to be deleted actually gets it deleted — not hidden behind a deletedAt timestamp while the email, name, and history sit indefinitely in the database. CNIL fined Clearview AI €20M in 2022 in part for failing to act on erasure requests, and ICO enforcement routinely issues multi-million-pound penalties on the same grounds. Beyond regulatory exposure, the Apple App Store and Google Play Store have both mandated in-app account deletion since 2022: apps that gate deletion behind a support-email workflow get rejected at review. AI coding tools reliably scaffold signup, login, and password reset, then skip the deletion route entirely — because "how do I build auth" is a well-represented training pattern and "how do I build GDPR-compliant erasure" is not. The quiet failure mode is a live app that passes every happy-path test while accumulating unlawful retention exposure with every new user.

Ship an authenticated DELETE route (e.g. app/api/account/route.ts) that either hard-deletes the user row with cascades to related PII-bearing tables, or anonymizes in place (email = null, name = 'Deleted user', pii_purged = true). If you soft-delete first, add a scheduled purge job that runs after a documented 14–30 day grace period and removes the underlying data across every table, object-storage bucket, and third-party processor that holds it.

Deeper remediation guidance and cross-reference coverage for this check lives in the gdpr-readiness and ccpa-readiness Pro audits — run those after applying this fix for a more exhaustive pass on the same topic.

• ID: project-snapshot.legal.account-deletion-coded
• Severity: critical
• What to look for: First determine whether accounts exist — auth library in package.json (next-auth, @clerk/*, @supabase/supabase-js, lucia, auth0, firebase/auth, better-auth), OR auth routes (/auth/*, /signup, /login), OR User/Account model in prisma/schema.prisma or users table in migrations. If no accounts, skip. If accounts exist, enumerate: (a) a DELETE handler at app/api/user/*, app/api/account/*, app/api/me/*, pages/api/user/*, or a server action matching /^(delete|anonymize|purge)(Account|User|Me)$/i; AND (b) the handler must actually remove or anonymize PII — prisma.user.delete(...), supabase.auth.admin.deleteUser(...), DELETE FROM users, or UPDATE users SET email = null / pii_purged = true / name = 'Deleted'.
• Pass criteria: Accounts exist, authenticated DELETE endpoint or server action exists, and the body performs real deletion / anonymization / soft-delete-plus-purge-cron.
• Fail criteria: Accounts exist and either no deletion endpoint OR the endpoint only flips deletedAt / isDeleted with no paired purge job (no route under app/api/cron/* or supabase/functions/* that purges past-grace-period rows). Soft-delete without a scheduled follow-up is not erasure.
• Skip (N/A) when: No accounts. Quote: "No auth library, auth routes, or user model — project has no user accounts".
• Before evaluating, quote: Deletion handler file path + 1–3 line excerpt showing the operation. If no handler, quote the auth evidence proving accounts exist.
• Report even on pass: "Deletion handler at <path>; mechanism: hard-delete | anonymize | soft-delete+cron at <cron-path>".
• Detail on fail: "next-auth present, /login route exists, but no DELETE endpoint under app/api/user/, account/, or me/" or "app/api/account/route.ts only runs prisma.user.update({ data: { deletedAt: new Date() } }) — no purge cron".
• Remediation: Ship an authenticated DELETE at app/api/account/route.ts that hard-deletes (with cascades), anonymizes-in-place (email = null, name = 'Deleted user', pii_purged = true), OR soft-deletes paired with a scheduled purge after a 14–30 day grace period across every table, storage bucket, and third-party processor. Deeper coverage: gdpr-readiness, ccpa-readiness.