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fix: retirement PII leaks by redacting pending secondary email/name data#38427

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fix: retirement PII leaks by redacting pending secondary email/name data#38427
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@ktyagiapphelix2u ktyagiapphelix2u commented Apr 23, 2026

Summary

This PR closes privacy gaps in the retirement flow related to secondary email and associated pending records in the LMS.

It ensures all retirement entry points consistently redact sensitive fields before deletion, so no plaintext PII is retained after records are removed.

Ticket & Reference

https://2u-internal.atlassian.net/browse/BOMS-499

@ktyagiapphelix2u ktyagiapphelix2u marked this pull request as ready for review April 23, 2026 11:29
@ktyagiapphelix2u ktyagiapphelix2u requested a review from a team as a code owner April 23, 2026 11:29
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Thanks. Some comments to get started...

.. pii: Contains new_secondary_email, not currently retired
.. pii: Contains new_secondary_email, redacted in `DeactivateLogoutView`
.. pii_types: email_address
.. pii_retirement: retained
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@bmedx: [inform] This doesn't seem like it would have been intentionally retained, so I'm fine with calling this a bug and just fixing. Any objections?

account_recovery.secondary_email = f"redacted+{user_id}@redacted.com"
account_recovery.is_active = False
account_recovery.save(update_fields=['secondary_email', 'is_active'])
account_recovery.delete()
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@ktyagiapphelix2u: Is it true that the recovery email itself is not yet redacted? I thought it was just pending secondary email updates. If so, I think secondary (recovery) email and pending secondary email should be separate PRs.

Also, it look like you wish to delete where we weren't previously doing so. @bmedx: Any strong opinions either way? In general are we redacting and leaving things in place?

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@ktyagiapphelix2u: You did not respond on this comment in particular, but from elsewhere, I think you want this all to stay together, right?

Also, I missed the earlier cls.objects.get(user_id=user_id).delete(), so we're not changing anything, but just adding redaction, right? Again, maybe use the simpler redact-before-delete email I proposed earlier?

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Thanks for the follow-up. To address your points:

  1. Same PR- Yes, both changes (recovery email + pending secondary email) address the same retirement gap and follow the same redact-before-delete pattern, so keeping them together makes sense.

  2. Simplified redact-before-delete, setting is_active = False before delete() was pointless (the row is gone immediately after). I've removed it, so retire_recovery_email now matches the simpler pattern used in redact_and_delete_pending_secondary_email, redact the email field, save, then delete.

Comment thread common/djangoapps/student/models/user.py
"""
Retire user's recovery/secondary email as part of GDPR Phase I.
Redact user's recovery/secondary email as part of GDPR Phase I.
Returns 'True'
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No longer returns True in all cases. Fix.

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got it implemented

def retire_recovery_email(cls, user_id):
"""
Retire user's recovery/secondary email as part of GDPR Phase I.
Redact user's recovery/secondary email as part of GDPR Phase I.
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This should "Redact and delete" if we leave the delete.

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DONE IMPLEMENTED

Comment thread common/djangoapps/student/models/user.py
# Assert that there is no longer a secondary/recovery email for test user
assert len(AccountRecovery.objects.filter(user_id=self.test_user.id)) == 0

def test_user_can_deactivate_pending_secondary_email_change(self):
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I'm holding off on reviewing tests. I'm getting confused between the pending and actual records, and this will be simpler when the PRs are split. Also, feel free to get an approval from the team first.

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Helpful Info

This PR fixes a PII leakage issue affecting two related models that store secondary email data at different lifecycle stages. The AccountRecovery model stores confirmed/active recovery emails, while PendingSecondaryEmailChange stores unconfirmed email change requests (before the user clicks the activation link).

During user retirement, we must handle both models because a user can have: (1) only a confirmed email, (2) only a pending change request, (3) both (when changing their existing recovery email to a new one), or (4) neither.

Both models require the same fix pattern: redact the email field to prevent PII from syncing to downstream systems save the redacted record, then delete it. The methods are idempotent, they return True if no record exists. For review clarity, I recommend examining the AccountRecovery changes first (confirmed emails), then PendingSecondaryEmailChange (pending emails), and finally the retirement flow that calls both methods.

Comment on lines +894 to +897
pending_secondary_email_change.new_secondary_email = get_retired_email_by_email(
pending_secondary_email_change.new_secondary_email
)
pending_secondary_email_change.save(update_fields=['new_secondary_email'])
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activate_secondary_email is a normal user action (clicking the confirmation link), not a retirement path. get_retired_email_by_email() produces a retired_<hash>@retired.invalid value. If a downstream system snapshots this deletion, it will see a retirement-style hashed email even though the user was never retired — this will produce confusing audit trails and could trigger false-positive retirement detection in downstream systems.

This change does not belong in this view. The soft-delete protection goal is valid, but the redaction function must not be get_retired_email_by_email() on a non-retired user. Either use a neutral placeholder, or remove this from the activation path entirely.

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right—activate_secondary_email is a normal user action, not a retirement flow. Using get_retired_email_by_email() here would incorrectly mark a regular user as “retired” in downstream systems, which could cause confusion or false positives.

I’ve removed the redaction from this path, so now the pending secondary email is just deleted after activation, with no retirement-style hashing. Redaction only happens in actual retirement flows.

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What about something like using completed@delete-pending.com? If the user is later retired, this soft-delete would persist, and isn’t that the case we’re trying to fix?

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@ktyagiapphelix2u: Did you see my comment? Can you acknowledge and respond? Thank you.

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I've implemented your suggestion. The pending secondary email is now overwritten with "completed@delete-pending.com" before deletion.

does not use get_retired_email_by_email(), so it won't be mistaken for a retirement hash or trigger false-positive retirement detection downstream

pending_secondary_email = cls.objects.get(user_id=user_id)
except cls.DoesNotExist:
return True
pending_secondary_email.new_secondary_email = f"redacted+{user_id}@redacted.com"
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But PendingEmailChange redaction (PR #38426) and management.py activation both use get_retired_email_by_email(). The edX retirement system has a standardized hashing approach for a reason — it's deterministic, auditable, and consistent across the retirement pipeline. Using a raw format here:

Produces .com domain (use .invalid if using a custom format)
Is inconsistent with the rest of the retirement system in this same codebase
Means downstream audits see two different redaction patterns for the same retirement flow
Both retire_recovery_email and redact_and_delete_pending_secondary_email should use get_retired_email_by_email(record.secondary_email) / get_retired_email_by_email(record.new_secondary_email) to stay consistent.

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  1. I'm not finding the PR description useful. I wish you'd simply write yourself the simple list of cases that you are fixing.
  2. I'm not clear if we are fixing the redact-before-delete for pending records that are activated during normal flow, and not during user retirement. I'm not seeing that (maybe I just missed it), but I thought that was a problem. and that we'd be calling the same code.
  3. Because we are simply redacted a deleted record that should never be seen, unless someone goes and looks at the soft-deleted records in downstream (in our case Snowflake), the redacted value is less important to be using the get_retired_email_by_email() function. I could imagine a simple hard-coded string like redact-before-delete@redacted.com.

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  1. is_active = False removed pointless before delete(), dropped from retire_recovery_email
  2. get_retired_email_by_email() used in both retirement methods — consistent with the rest of the retirement pipeline
  3. Activation path uses neutral placeholder "completed@delete-pending.com" not a retirement hash, no false-positive signals
  4. Docstrings updated "Redact and delete", correct return type, proper descriptions
  5. except DoesNotExist now returns True consistent early-return pattern in both methods
  6. Unused import removed get_retired_email_by_email import dropped from management.py

Comment thread openedx/core/djangoapps/user_api/accounts/views.py Outdated
Comment thread common/djangoapps/student/tests/test_models.py Outdated
Comment thread openedx/core/djangoapps/user_api/management/tests/test_retire_user.py Outdated
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@ktyagiapphelix2u: I added some top-level comments before starting this review. Please respond to those as well. Thank you.

Comment on lines +1746 to +1747
Note: "Retire" here refers to retiring this user's data, not the recovery email
feature itself, which remains available for new accounts.
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Not sure what "the recovery email feature itself" means. Here is my proposed update:

Suggested change
Note: "Retire" here refers to retiring this user's data, not the recovery email
feature itself, which remains available for new accounts.
Note: In retire_recovery_email, "retire" means this is part of user retirement.
The recovery email itself remains available for use with future accounts.

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@ktyagiapphelix2u ktyagiapphelix2u May 12, 2026

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Implemented

Comment thread common/djangoapps/student/models/user.py
account_recovery.secondary_email = f"redacted+{user_id}@redacted.com"
account_recovery.is_active = False
account_recovery.save(update_fields=['secondary_email', 'is_active'])
account_recovery.delete()
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@ktyagiapphelix2u: You did not respond on this comment in particular, but from elsewhere, I think you want this all to stay together, right?

Also, I missed the earlier cls.objects.get(user_id=user_id).delete(), so we're not changing anything, but just adding redaction, right? Again, maybe use the simpler redact-before-delete email I proposed earlier?

Comment on lines +1757 to +1758
account_recovery.is_active = False
account_recovery.save(update_fields=['secondary_email', 'is_active'])
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Messing with is_active is simply confusing. We're about to delete this row, so in theory we don't need to make any changes. The only reason we are touching the record before deleting is to not leave PII in soft-deleted records downstream. Let's keep this simple.

Suggested change
account_recovery.is_active = False
account_recovery.save(update_fields=['secondary_email', 'is_active'])
account_recovery.save(update_fields=['secondary_email'])

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@ktyagiapphelix2u ktyagiapphelix2u May 4, 2026

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Implemented

@ktyagiapphelix2u ktyagiapphelix2u force-pushed the ktyagi/secondaryemail branch from 84d0cf9 to 6320d0b Compare May 12, 2026 11:07
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