docs/reference/purge_subcommand.md: misleading — --kind logs is **intentionally absent**: audit logs are append-only Article 17(3)(b) records and are not deleted by the tool. (DOC-BLEGAL-017) #134

Wave 1 · theme D1-10: Documentation-only fixes · highest severity High · 1 finding(s) · effort docs fix

Summary

Controllers may refuse erasure of personal data in audit logs on the basis of a blanket exemption that does not exist.

Primary finding

DOC-BLEGAL-017 — docs/reference/purge_subcommand.md: misleading — --kind logs is intentionally absent: audit logs are append-only Article 17(3)(b) records and are not deleted by the tool.

severity High

Where. docs/reference/purge_subcommand.md:53 (Turkish mirror: docs/reference/purge_subcommand-tr.md:53) · type: misleading

The document says. --kind logs is intentionally absent: audit logs are append-only Article 17(3)(b) records and are not deleted by the tool.

What the code does. GDPR Art. 17(3)(b) disapplies erasure only 'to the extent that processing is necessary ... for compliance with a legal obligation which requires processing by Union or Member State law' (or a public-interest or official-authority task). It depends on a specific legal obligation that requires the processing. It does not depend on the log being append-only and does not apply automatically to an operational log.

User impact. Controllers may refuse erasure of personal data in audit logs on the basis of a blanket exemption that does not exist.

Proposed correction. --kind logs is intentionally absent: the tool never deletes audit-log entries (append-only design). Whether retaining personal data in them is exempt from erasure under GDPR Art. 17(3)(b) depends on a specific Union or Member State legal obligation that requires the retention (for example AI Act log-retention duties for high-risk systems), and only to that extent and for that period.

Turkish mirror. the Turkish page has the same error; fix both in the same PR

Acceptance criteria

• Each statement is re-checked against the code at fix time.
• Documentation listed above is corrected in English and in its Turkish mirror in the same PR.
• Every finding in this issue is resolved or explicitly closed with a reason.

_{Found by the October 2026 ForgeLM code and documentation review against commit cab2947. Code links point at that commit; line numbers may have moved since. Finding IDs (CR-…, DOC-…, TECH-…) are stable references for this backlog.}