Account deletion in apps and customer portals: Apple, Google Play and GDPR requirements in one design

Apple’s requirement

Apple’s App Store Review Guidelines require apps that support account creation to also let users initiate deletion of their account from within the app. Apple began enforcing this requirement for app submissions from 30 June 2022.

Apple’s guidance says that deleting an account should delete the account record along with associated personal data, not merely deactivate it. Apps in highly regulated industries may use additional customer service steps to confirm deletion, and apps may explain data that must be retained for legal reasons. The option should be easy to find, usually in account settings.

Google Play’s requirement

Google Play introduced a comparable data deletion policy. Apps that allow users to create accounts must provide a way to request account deletion from within the app and a web resource, linked in the Play Console data safety section, where users can request deletion of their account and associated data without reinstalling the app.

Developers had to provide this information from December 2023, with extensions available until 31 May 2024. The web link matters for users who have already uninstalled the app but want their data removed.

In-app path

A discoverable option to request account deletion inside the app.

Web link

A web page where users can request deletion without the app.

Data safety disclosure

Information in the store listing about data deletion and retention.

Partial deletion

Where offered, the option to delete some data without deleting the account.

The GDPR right to erasure

Under Article 17 of the GDPR, individuals have the right to have personal data erased without undue delay in several situations, including when the data is no longer necessary for its purpose, when they withdraw consent and no other lawful basis applies, or when they object to processing and there are no overriding legitimate grounds.

The right is not absolute. Data may be retained where processing is necessary to comply with a legal obligation, such as tax and accounting retention for invoices, or for the establishment, exercise or defence of legal claims. Controllers must respond to requests within one month, extendable in certain cases, and inform the individual of the outcome.

For businesses operating customer portals or web accounts without an app, the GDPR requirement applies even though app store policies do not. A self-service deletion option is not strictly required by the GDPR, but it is the most reliable way to handle requests efficiently.

Designing a single deletion flow

Place the deletion option in account settings in the app and web portal, and provide a public web page for users without access. Explain clearly what will be deleted, what must be retained and why, what happens to active subscriptions, and whether deletion is immediate or follows a short grace period.

Confirm the request with an authentication step to prevent abuse, and send a confirmation when deletion is complete. If a subscription is billed through Apple or Google, remind users that deleting an account does not automatically cancel store subscriptions, and link to the relevant subscription management settings.

Where some data must be retained, separate it from the active account: keep invoices and transaction records in accounting systems with restricted access, and delete or anonymise profile data, preferences, messages, uploaded content and marketing data.

Deleting data everywhere it lives

Account deletion is rarely confined to one database. User data may be copied to the CRM, email marketing platform, analytics, customer support tools, push notification services, data warehouse, backups and third-party processors.

Build deletion as a process that propagates: an event or job that removes or anonymises the user in each connected system, with logs showing what was done. Keep a minimal suppression record where needed, for example to honour a marketing objection or prevent re-importing the person from an old list.

Backups can usually expire on their normal cycle, provided restored data is re-processed against deletion records. Document this in the privacy notice and internal procedures.

Testing and review

Test deletion end to end: create an account with typical data, delete it, and verify that data is removed or anonymised across systems while legally required records remain. Repeat after major releases and integration changes.

App store reviewers also test deletion paths, and a broken or hidden option can delay app approval. A clear, working flow avoids rejections and support tickets and shows users their data is handled with care. This article is a general overview and not legal advice.

Where this sits in what we do

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