> Does Apple have any way to verify it’s actually a full delete, and do they do so?
The guidelines do state that it should be a full delete. In my experience, Apple has never checked or asked to verify if a user account was fully deleted on apps I've worked on, which involve PHI. It's been a part of HIPAA compliance for our apps since the beginning (and we do actually fat delete, FWIW). It's a relatively new requirement from Apple's end, though. The deadline was actually extended from January 31st 2022 to now June 30th 2022. Enforcement or stringency on Apple's part could change around then, but I don't see Apple having the resources or willpower to do much of an increase here.
The guidelines do state that it should be a full delete. In my experience, Apple has never checked or asked to verify if a user account was fully deleted on apps I've worked on, which involve PHI. It's been a part of HIPAA compliance for our apps since the beginning (and we do actually fat delete, FWIW). It's a relatively new requirement from Apple's end, though. The deadline was actually extended from January 31st 2022 to now June 30th 2022. Enforcement or stringency on Apple's part could change around then, but I don't see Apple having the resources or willpower to do much of an increase here.
Full guidelines are here: https://developer.apple.com/news/?id=i71db0mv