It feels like that, but I wonder how long it will be before one of the regulators decides to make an example of one of the big data-hoarding companies. Their whole business model is morally and now also legally dubious, and it's so obviously against the spirit of the GDPR that it seems like a matter of time before someone decides to pick a fight. I doubt it will be a single case like yours that starts it, unless perhaps it provides a convenient excuse to start an investigation, but it will be a thousand or a million situations like yours that motivate it.