Thanks for the comment. It actually perfectly illustrates my point. Most people equate GDPR with a "Delete My Account" button, but that’s just the tip of the iceberg.

We didn't spend thousands of hours on a deletion feature (or just development time). We spent them in total to be compliant in a healthcare environment. That time goes into:

Documenting the entire lifecycle (how, why, and where) of every single data point we process. Conducting and documenting formal risk assessments for every major processing activity (Privacy Impact Assessments (DPIA)). Drafting and negotiating data processing agreements (DPAs) with every single partner and vendor we use. Building strict role-based access and logging systems to track exactly who views and edits data and why. Implementing pseudonymization and logical data separation to ensure we meet "privacy by design" standards. Constantly coordinating between the product and dev team and the DPO to update policies and communicate changes to users.

The point I’m making is that the EU has built an incredibly expensive regulatory environment to support rights that, in practice, the vast majority of users don't seem to care about. We’re over-engineering for a "loss of control" that the average user hasn't shown much interest in reclaiming.

Those things are all necessary anyway, apart from the last one (communicate to users) which absent GDPR is a nice-to-have. If you don't do them, or something equivalent to them, then your processes will be wrong and you'll have breaches – and breaches of healthcare data are extremely bad. What GDPR gives you is the assurance that you won't be at a competitive disadvantage for doing the bare minimum due diligence, because your competitors are required to do so, too.

> We spent thousands of hours building systems for rights that only 0.001% of our users cared to use.

GDPR does not require that any of the data subject rights are automated, other than "right to be informed" (which it doesn't explicitly spell out has to be automated, but "put the information on the website" is the easiest way to comply if you're relying on the consent basis for anything). If you expect that under 200 people are ever going to exercise a particular right, and automation will take longer than manually fulfilling those requests, then don't automate them: just add it to your DPO's job description.

> that, in practice, the vast majority of users don't seem to care about.

You can't use "people are choosing not to waste the time of a healthcare provider" as an argument that people don't care. They may simply be being kind. I very rarely require GDPR data subject access requests, but when I do, it's very important that I can get them in a timely manner.

If I know what information is kept by the organisation (and therefore would be included in the GDPR request), and there are other ways of me accessing the information I care about having, I don't need to perform a GDPR request. It's organisations where there aren't where I'm most likely to need to make a GDPR request. If a company is actually complying with data minimisation and purpose limitation, I do not need to make a GDPR deletion request. etc etc. I think you're focusing on how annoying it is for you, and not thinking of the impact on your less-ethical competitors (who might otherwise be able to run you out of business – depending on the industry).

I'd wager it's less expensive than US medical services.