zlacker

[parent] [thread] 7 comments
1. gnud+(OP)[view] [source] 2018-05-18 09:42:23
Run your small company website without gathering personal data?

No-one can sue you now, that couldn't before. I'm baffled that so many people believe this. I could complain about you to my country's regulation body. Then they could decide to audit you, and for a first offense issue a warning.

If you need the address data for marketing only, and you didn't get an explicit (opt-in) yes to receive marketing, then sorry. Get that explicit opt-in yes in the next week, or delete the data.

If you need the address data for other reasons, for example fullfilling your contract with the customer, or tax records, then keep it. But _only use it for those real reasons_. No free marketing lists. Sorry.

Storing an IP for a limited time for security reasons is fine. Have rules in place for how this data is used and when it is deleted. Don't keep it longer than nessescary.

Google seems to think you can still use Fonts. They also seem to think like they will be the data controller, and not data processor, for any user data they scoop up [1]. This seems a bit weird to me. This is the only one of your questions that I'm really not sure about. If it was me, I would just host the font locally so I was sure.

1: https://github.com/google/fonts/issues/1495#issuecomment-382...

replies(2): >>zerost+u1 >>halr90+Je
2. zerost+u1[view] [source] 2018-05-18 09:58:05
>>gnud+(OP)
> No-one can sue you now, that couldn't before.

That is not true, GDPR is a law, and in the past most EU countries did not have such stringent requirements. You couldn't be sued (Edit: i mean by the DPA).

replies(1): >>gnud+72
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3. gnud+72[view] [source] [discussion] 2018-05-18 10:05:34
>>zerost+u1
My point is that you won't be sued for the GDPR. What might happen is that a complaint is raised with the regulatory body. This is not the same thing as being sued.
4. halr90+Je[view] [source] 2018-05-18 12:41:41
>>gnud+(OP)
I liked the aisle, but have a lot of issues with it. This is one of my main ones: IP addresses and information security. Quoting you:

> Storing an IP for a limited time for security reasons is fine. Have rules in place for how this data is used and when it is deleted. Don't keep it longer than nessescary.

How long is necessary? What does limited mean? Does a regulator now get to determine what sort of algorithms I can use to protect my assets? Advanced persistent threats (https://en.m.wikipedia.org/wiki/Advanced_persistent_threat) can exist over a very extended--and arbitrary time period! I'm in the security software industry, and we and our customers need to detect and react to these threats. That requires data which you simply cannot obtain an opt-in for. Sure, you put that in a posted privacy policy, but if you can only keep the data for 30 days, this means actual evidence of a crime might need to be thrown out.

replies(1): >>shabbl+xE
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5. shabbl+xE[view] [source] [discussion] 2018-05-18 16:07:03
>>halr90+Je
> How long is necessary?

As long as is needed for the stated purpose. If you're doing IP-based rate limiting with a 1 hour window, it probably doesn't need to still be in your systems >12 hours from now. If you're doing longer term IP reputation or something, keeping it around longer can probably be justified.

> What does limited mean?

The same. Long enough to serve its purpose, and no longer (without justifiable exception, such as being evidence of an actual crime, etc)

> Does a regulator now get to determine what sort of algorithms I can use

Not really, any more than they already do.

"Not guilty, Your Honour; you see, we do store people's HIV status against their real names on the public blockchain, but don't worry, it's ROT-13 encrypted! Twice!"

Also, remember that it's not really the IP that you care about (from a privacy perspective). An IP+timestamp is a very discerning selector, if you have any other data at all.

Nobody knows that '192.168.1.1' is actually me. And even if they did, does it really matter?

But maybe they know that only $IP hit /orders/confirm within 5 minutes of some other system recording that $ME placed an order with other details.

From a privacy standpoint, it's your ability to cross-correlate that IP and whatever else you know about it that could allow identifying and tracking/profiling the actual person using it.

Suppose your marketing dept asked you to scan the last few weeks of security logs to see if you'd had any hits from ranges belonging to $BIGCORP who you're in tense negotiations with? Is that Ok? Or would you refuse because the security logs are collected exclusively for certain purposes of which that isn't?

replies(1): >>apple4+Ml1
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6. apple4+Ml1[view] [source] [discussion] 2018-05-18 21:47:51
>>shabbl+xE
That is silly. IP addresses should not be covered. I should be able to keep IPs for years. They change often anyway.

IP addresses being covered is one of my big issues with GDPR.

replies(2): >>jacque+no1 >>shabbl+hr1
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7. jacque+no1[view] [source] [discussion] 2018-05-18 22:19:06
>>apple4+Ml1
Then you're going to love HIPAA. That's a US law by the way.
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8. shabbl+hr1[view] [source] [discussion] 2018-05-18 22:53:05
>>apple4+Ml1
what value do you get from keeping them for years? Are you actively analysing and re-analysing them for any particular purpose, or is it more of a 'well, you never know...' sort of deal?

"they change often" is arguably a good reason for not keeping them. What advantage do you get from knowing that 10 years ago $IP was sending you spam if it's been though 20 different re-allocations and tens of thousands of 'actual owners' since then?

Imagine if google or cloudflare were logging every since query to their public DNS and correlating it with other access logs or google analytics or whatever. They'd be able to relatively trivially deanonymise huge numbers of actual people's identities and browsing history (beyond what they can obtain already).

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