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Ask HN: How do you GDPR for your small side projects?

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41–50 of 54 posts

Re: Ask HN: How do you GDPR for your small side projects?

#41

All the most important data that shouldn't be for my eyes -- is 256-bit encrypted as it gets entered into any database. All passwords and most user-inputted data is encrypted. Stripe takes care of the payment information which I don't store, but I do keep the expiration date in my database which usually cannot be used to identify anything. Definitely trying to be more GDPR-compliant as I take privacy and security ver…

> All passwords [...] is encrypted.

Hopefully you're storing encrypted hashes and not simply encrypting passwords.

Re: Ask HN: How do you GDPR for your small side projects?

#43
It's not too tricky, fortunately!

1. Stop collecting any data you don't need. If you don't collect it, it's not an issue!

2. Have a way for users to access their data or request it be deleted. This can be a manual process.

3. Make sure you gain explicit consent for any data you capture from users, and explain why you are using it.

4. Make sure any data you capture is stored securely using industry best practices.

5. Put a retention policy in place for backups and logs – for example, delete them after 30 days.

That's basically it. It's more complex if you have a product that needs to store lots of data to function, or if you have a sprawling set of databases, or if you have some kind of un-deletable storage. But in general, you only need to do the sort of things that you should really already be doing if you use personal data.

And bear in mind that the goal of GDPR is not to fleece companies for fines, but to achieve compliance with the rules. If you do something wrong but act in good faith, you can expect a letter from whichever SA is coming after you. But you're not going to see a €20m fine any time soon.

Re: Ask HN: How do you GDPR for your small side projects?

#44

Blackhole all connections from Europe.

Or, you know, just do the minimum amount of effort to not be a jackass with your users' data…

When simply including an IP address in a system log file counts as tracking a user's private information, "not [being] a jackass" is meaningless.

Re: Ask HN: How do you GDPR for your small side projects?

#45

It's not too tricky, fortunately! 1. Stop collecting any data you don't need. If you don't collect it, it's not an issue! 2. Have a way for users to access their data or request it be deleted. This can be a manual process. 3. Make sure you gain explicit consent for any data you capture from users, and explain why you are using it. 4. Make sure any data you capture is stored securely using industry best practices. 5.…

> Stop collecting any data you don't need. If you don't collect it, it's not an issue!

That's trickier than it sounds.

If you embed a copy of jQuery on your page hosted by a CDN, you're collecting and sending personal data to the CDN. Do you have consent for that?

Same with web fonts, icon fonts, javascript libraries, social media follow/share buttons, analytics tags, etc you embed in the tags.

Every time your page is loaded, you're sending personal data to all those third parties, most of them not even located in the EU, which means you're sharing with a third party and doing a cross-border transfer.

You need more than just consent to do that, they're sub-processors for you, and you likely need signed Data Processing Addendums with each of those companies, and they need to have adequate protections for cross-border data transfers, like participation in the EU-US Privacy Shield Framework. Have you signed those agreements?

You can easily be sharing more data than you meant to, too. Let's say you send a newsletter for your website and you host a copy of phpList or similar software to manage and send it. In each mail you send out, you include an unsubscribe link, which has the address to unsubscribe embedded in the link.

When someone clicks that link, their email address will be part of the HTTP referrer header sent to all those third party scripts on your page. Now you're transferring email addresses to a half dozen third parties with no legitimate business reason to do so. Do you have consent to do that?

Re: Ask HN: How do you GDPR for your small side projects?

#46
post #24
post #23

If you have a project that doesn't allow users to enter any kind of information but simply displays ads (via Adsense), is that in scope for GDPR or is a proper Privacy Policy enough?

Do you set cookies that are not functionally required for the site to operate? Have to allow opt-in and opt-out of those cookies. Adsense cookies almost certainly fall into this bucket. Do you set cookies that are required? Need to identify them and inform the user. Server logs? You probably have ip addresses. Despite what us nerds think the EU considers them personal data.

Thanks for the answer. The only cookies are adsense and those are functionally required to run the site (as it's the only revenue stream). I already use a cookie banner for that.

I run the site behind cloudflare and don't store X-Forwarded-For IP, the analytics software I use immediately anonymizes them before storing them. So I should be fine I hope.

Re: Ask HN: How do you GDPR for your small side projects?

#47

Earlier quoted context omitted.

You live in EU? Sure. You live in US? Nope, it does not apply. There's no nexus. EU can go and pound sand.

That's not correct. As soon as you want to do business with someone currently located in the EU (doesn't even have to be an EU citizen), GDPR applies, no matter where your company is located.

I have quite enough to do to comply with my own country's laws, thank you very much. Where would this end? Would I eventually need to know the laws of every nation so that I can do what you feel is ethical? Or do I just follow other countries' laws if they make headlines or get talked about a lot? I'll be following the IDGAF process on this one.

Re: Ask HN: How do you GDPR for your small side projects?

#48
post #47

Earlier quoted context omitted.

That's not correct. As soon as you want to do business with someone currently located in the EU (doesn't even have to be an EU citizen), GDPR applies, no matter where your company is located.

I have quite enough to do to comply with my own country's laws, thank you very much. Where would this end? Would I eventually need to know the laws of every nation so that I can do what you feel is ethical? Or do I just follow other countries' laws if they make headlines or get talked about a lot? I'll be following the IDGAF process on this one.

It's actually quite simple.

If you don't want to do business with someone from another country you certainly don't have to comply with other countries' laws. If on the other hand you do sell a product or service to businesses or people abroad you have to comply with the relevant laws of their respective home countries.

That's not a new or GDPR-specific situation but rather has been the case since pretty much the beginning of international trade.

Re: Ask HN: How do you GDPR for your small side projects?

#49
post #47

Earlier quoted context omitted.

I have quite enough to do to comply with my own country's laws, thank you very much. Where would this end? Would I eventually need to know the laws of every nation so that I can do what you feel is ethical? Or do I just follow other countries' laws if they make headlines or get talked about a lot? I'll be following the IDGAF process on this one.

It's actually quite simple. If you don't want to do business with someone from another country you certainly don't have to comply with other countries' laws. If on the other hand you do sell a product or service to businesses or people abroad you have to comply with the relevant laws of their respective home countries. That's not a new or GDPR-specific situation but rather has been the case since pretty much the begi…

Simpler: I put my dumb thing on the web. I do not care who you are. I do not care where you are. I don't waste my energy giving it another thought.

"I got a letter from your government the other day. I opened and read it. It said they were suckers..." On a serious note though, regulation is already onerous to small (and very small) business. The last thing a rational entrepreneur would do is tie themselves up with more of it voluntarily. Unless you can present a reason to do so that is not sanctimonious.

Re: Ask HN: How do you GDPR for your small side projects?

#50

Earlier quoted context omitted.

EU can write any law it wants. It cannot enforce it on anyone who is not have a nexus to EU. Any hobby that gets to a point of making money in EU gets a nexus. Everything else is a FUD. Facebook, Google, Apple, etc all have nexus which is why it is applicable to them. JoeSchmoeLLC from Delaware does not.

Just because something isn't easily enforceable it doesn't become legal or ethical. A small company absolutely can get by with shoebox accounting, too, it's just not particularly advisable to do so. The same applies to completely ignoring GDPR, whether it's enforceable or not.

> The same applies to completely ignoring GDPR, whether it's enforceable or not.

It is as laughable as it gets. Let me guess:

1. You never cross a street not on a crosswalk 2. You never drive above speed limit 3. You never signup for the same website twice if their TOS say "you shall have only one account"? ...

And so many other silly statements.

Laws are only useful if they cab be enforced. This law cannot be enforced against any entity not in jurisdiction.

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