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Show HN: Kate's App

katesapp.org

151–160 of 192 posts

Re: Show HN: Kate's App

#152
post #58

Earlier quoted context omitted.

> The second is a bit more complicated, since multiple family members may have access to the same data, and may have different opinions on deleting it. I'll work it out. I know it's been said elsewhere, but you need a lawyer. This isn't something for you to work out, it's something for you to clearly understand your legal obligations, and what your exposure is based on which jurisdictions a user might log in from.

As someone under civil law jurisdiction, I have a hard time parsing this: > This isn't something for you to work out, it's something for you to clearly understand your legal obligations Like, is it really impossible to "understand your legal obligations" without help from a lawyer? Is it supposed to be like that? Why? Are the laws explicitly written to be impossible to understand if you're not a lawyer? I might have…

This service is currently running, in production, in the United States, and is missing key features that are regulatory or legal requirements. I won't enumerate them because I work in security, not privacy or compliance (although those are features that require strong security and I often support related projects).

The app is designed to allow sharing of personally identifiable information, and apparently doesn't distinguish regions, age, etc.

Assuming OP is American, and hosting the service in the US, and given the target audience and proposed use case, I can think of a couple of regulations that apply:

  FTC Act
  COPPPA
  CCPA
  All of the privacy laws documented here:   https://iapp.org/resources/article/us-state-privacy-legislation-tracker/
In addition, if a Canadian user signs up, then PIPEDA, and various other regulations come into play.

If an EU user signs up, then obligations must be met under the FTC's Data Privacy Framework and compliance with various EU and national regulations come into play.

It's not impossible for someone to adhere to all of the laws, it's just a full time job to do it. It's probably not reasonable for a single person to build and operate a service with the privacy and security requirements and claims that the author of KatesApp makes, and meet the compliance requirements. It is abundantly clear to anyone who works in privacy or security that the website doesn't meet the bare minimum requirements, and has very little standing to defend itself.

For reference for anyone who hasn't signed up for it, there is no terms of service, and no privacy policy.

The service includes features to allow uploading of data related to:

  Prescriptions - medication, dosage, instructions, prescriber, and pharmacy
  Medical Appointments - who (presumably the medical professional), date/time, location, and reason for medical appointment
  Doctors - a list of doctors, clinic, contact info
  Upload files, with this helpful list of suggestions of medical records to upload:
   - insurance information
   - advanced directives or DNR/DNI
   - a copy of your vaccination card
   - lab test results, doctors' reports, x-ray, MRI, and CT    - scans, or other images
   - voice recordings of visits with the doctor or other providers
   - self-monitoring logs (sleep, diet, exercise, etc.)
There are logs to show who created a data element under each of those types of records, but I didn't test the site deeply enough to determine if there are any audit controls or logs that are visible to users on who accessed what, but the privilege system implemented is rudimentary, and is fundamentally weak due to the fact that user accounts are unverified.

Anyone can sign up and create and share files and resources using this service. From the main public page, the author requires a signup code, but signing up from the HN link on the post bypasses this. There is no validation of who the user is, no confirmation that the person who signed up owns the account, or options to delete my test account or data. There are no controls that appear to limit what might be uploaded other than file size.

As of right now, this site is in violation of Canadian law and EU laws regulations. I assume it is also in violation of American laws and regulations.

I understand what the author is attempting to do, and why they are doing it, and they are deserving of empathy (and in my other comment I provided them a road map to improve some of the security issues on the site), but launching a website into production that gathers this data, in the United States is not only unwise, it is probably negligent, and it's reasonable to expect that someone could sue the owner of the application.

From a user privacy and security perspective, a user of this service would quite literally have more protections and controls using a google spreadsheet or shared folder to store and share these documents.

Re: Show HN: Kate's App

#153
I feel like at minimum, the information should all be stored in encrypted, unavailable-to-an-admin way.

https://guides.rubyonrails.org/active_record_encryption.html

Basically, all the data in the app would be hidden to everyone except the users. I'm assuming this would be the case, and I'm assuming that you, with prod db access, wouldn't be able to directly read the text that is being written.

If that were the case, I'd say your ethical obligation is fulfilled, more or less. (obv implementing application-level 'everything is encrypted' is not trivial, but it makes it so that you couldn't ever see what was being said)

I don't believe in political authority, so when people say "But hipaa!" I hear "but I believe in the institution of authority" and I sorta tune out everything else that they say.

There's a LOT of people in the world who believe in authority/political authority, and it is tiring. sorry for us all.

This app is cool! Well done to you. Hope you don't have to spend thousands on lawyers and don't have to deal with coercive institutions based on the fantasy of political authority.

Re: Show HN: Kate's App

#155
Does this support FHIR? If not have you considered supporting it?

Many health care providers offer export of health records to FHIR format now. You can also retrieve those records on iOS via the HealthKit API.

Apple lets you log into your health care provider in the Health app and download all your records from supported providers. You can request access to those records from another app installed on your phone.

Re: Show HN: Kate's App

#156
post #3

If you're dealing with personal health information (PHI), I would advise you to temporarily close your site and hire a lawyer straight away. Whenever you touch this kind of data, regulatory regimes like HIPAA may apply, and you need to be extremely careful. There's not a HIPAA compliance or even a privacy policy statement available on your front page. See https://www.hhs.gov/hipaa/for-professionals/privacy/laws-reg..…

This is good advice. Beyond HIPAA and similar regulations, there's the broader challenge that part of the intended audience probably would not want to use it for the same reasons. Any health care professionals that handle information like this are subject to the same rules and would only use tools that comply to minimize liability. And there's the related problem of those people probably already having a lot of tools…

> people probably already having a lot of tools that they use and prefer. Another tool adds to their work load.

Further, a lot of providers are very strict about what tools their organization is allowed to use. In the past I’ve tried to get providers to look at a personal web page where I’d had a medical history and links to imaging data, and they weren’t allowed to access it via policy.

(I then brought 10 disks of imaging on a thumb drive - but they wouldn’t take that either. So I re-burned them onto physical media, and they were ok with importing that.)

I do understand why those policies are necessary, and in the end I learned their systems and limitations. It’s actually been an ok experience.

Re: Show HN: Kate's App

#157
post #152

Earlier quoted context omitted.

As someone under civil law jurisdiction, I have a hard time parsing this: > This isn't something for you to work out, it's something for you to clearly understand your legal obligations Like, is it really impossible to "understand your legal obligations" without help from a lawyer? Is it supposed to be like that? Why? Are the laws explicitly written to be impossible to understand if you're not a lawyer? I might have…

This service is currently running, in production, in the United States, and is missing key features that are regulatory or legal requirements. I won't enumerate them because I work in security, not privacy or compliance (although those are features that require strong security and I often support related projects). The app is designed to allow sharing of personally identifiable information, and apparently doesn't dis…

For the record: I don't disagree with anything above.

My question was more about whether you need a lawyer to know you need a privacy policy... It was tangential, admittedly; sorry about that.

To make the direction of the tangent clearer (and please ignore it if it distracts from the main discussion too much): I'm in the EU, and I know that I'd need to read GDPR[1] before letting people see such an app. I haven't read it - I quite possibly would give up at Act 4 and decide I do need a lawyer. But my first instinct would be to go read the Regulation itself.

[1] Actually, RODO (official translation): https://gdpr.pl/baza-wiedzy/akty-prawne/interaktywny-tekst-g...

Re: Show HN: Kate's App

#158
post #37
post #16

I don't want to repeat other comments here; but this app smells of a very dangerous attitude: Built with love by novices with grand intentions, with complete blindness to the real consequences that happen when novices are ignorant in their field. If your goal is to "find a learning project," I suggest finding a very different "learning project." Otherwise, keep "Kate's app" private, word-of-mouth, invite-only for und…

How do you know that the authors are novices with "complete blindness" to real consequences? Where are you getting the "find a learning project" goal from? It sucks that you've been burnt by that before, but it sounds like your employer was the one who screwed you there, not the author of the application.

From the blurb at the top: “ The app is 95% complete, […] I intend to clean up the rest of it, and go GA within a few weeks. ”

Assuming the last 5% is going to just take a few weeks is naive from a development point of view. Everyone learns this the hard way, so I don’t mean it as a dig.

Re: Show HN: Kate's App

#159
post #37

Earlier quoted context omitted.

How do you know that the authors are novices with "complete blindness" to real consequences? Where are you getting the "find a learning project" goal from? It sucks that you've been burnt by that before, but it sounds like your employer was the one who screwed you there, not the author of the application.

From the blurb at the top: “ The app is 95% complete, […] I intend to clean up the rest of it, and go GA within a few weeks. ” Assuming the last 5% is going to just take a few weeks is naive from a development point of view. Everyone learns this the hard way, so I don’t mean it as a dig.

[deleted]

Re: Show HN: Kate's App

#160
post #37

Earlier quoted context omitted.

How do you know that the authors are novices with "complete blindness" to real consequences? Where are you getting the "find a learning project" goal from? It sucks that you've been burnt by that before, but it sounds like your employer was the one who screwed you there, not the author of the application.

From the blurb at the top: “ The app is 95% complete, […] I intend to clean up the rest of it, and go GA within a few weeks. ” Assuming the last 5% is going to just take a few weeks is naive from a development point of view. Everyone learns this the hard way, so I don’t mean it as a dig.

Every completed project was at one point a few weeks away from being done.
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