@simon https://eur-lex.europa.eu/eli/reg/2016/679/oj#d1e1797-1-1 remember, this is a blanket text. Member-states can add but hot remove constraints.
Under general don't need a function to delete comments, but you need to have a [not necessarily automatic] way for a user to ask to delete all the comments and the information that they ever left any comments. I'll find the exact article and point in some minutes.
I'm very interested what LLM would say.