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GDPR – A Practical Guide for Developers (2017)

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Re: GDPR – A Practical Guide for Developers (2017)

#51

It's interesting to see how the GDPR seems to clash with some popular data models. For example, git. Rewriting history of a shared branch is disastrous, but it's currently the only way to redact, say, an e-mail address someone committed with a couple of years ago. I'm curious how the various code hosting sides plan to handle that. Perhaps we'll see an extension of the data model that links commits to committer UUIDs,…

I suspect preserving git history is allowed for the purpose of determining copyright compliance.

Re: GDPR – A Practical Guide for Developers (2017)

#52

What about Wikipedia? User accounts are linked with article edits/history. So if you delete the user how do you handle their edits?

Suppression[0] or similar tech. Delete the username associated with the edit, while keeping the diff around.

[0]: https://en.wikipedia.org/wiki/Wikipedia:Oversight

Re: GDPR – A Practical Guide for Developers (2017)

#53
post #3

GDPR and Kappa/event sourcing/message queue based/you name it architecture goes together nicely as you get audit logs of everything and it should be quite doable to propagate "delete this person's data" events around the place. It's a huge hassle compared to what many companies are doing with customer data now but I think it's for the best. Most things about GDPR go like "Does it feel a bit shady? It probably is. Don…

I didn't realize it until reading this post, but certain very popular technologies break GDPR in a deep way. Bitcoin, for instance, contains a wealth of personal information, which by design are both public, persisted forever, and immutable. Are blockchain products all going to need a full rewrite or a complicated hard fork? What about the Wayback Machine? Will they need to have an endpoint that every company will ne…

What personal information does bitcoin contain?

Re: GDPR – A Practical Guide for Developers (2017)

#54
I just want to point out that a lot of the article is the authors own opinion on how the regulation should be implemented into software and a lot of things are probably not needed normally and would be a burden for businesses.

My own take (and the take of most European data protection lawyers I meet) is that consent is not needed, and also possibly is inappropriate in 90% of the cases - instead the “legal basis” called “legitimate interest” should be used instead. This is where you do your own judgement if your data processing is reasonable. Imagine if you yourself always had to consent to all common sense use of your personal data, what a hassle!

If you use legitimate interest, also skip the “under 16” part, consent checkboxes and re-request consent part of the article (Of course there is more to it, but I would not get in to that unless you are doing data processing you do not think the data subjects in general would approve of).

Functions that allow the users to delete and automatically download/access their own data is good practice for legitimate interest but not needed. You are anyway in general allowed to deal with these types of request on a case by case basis if you provide your data subjects with an email address.

What you should do though is automatically delete data that you do not need anymore, such as old logs, customers contact details of customers long gone, old backups etc.

The parts of encyption, you should create an api etc are not required but may be good practice. Just make sure you have normal OK data and data access security.

As discussed above, you SHOULD use data for purposes that the customer has not agreed/consented to. However, never use personal data for purposes that are not compatible with the purposes you informed your customers of when collecting the data (normally stated in your privacy notice on your web site). If you did not have a privacy notice at the time of collection pre-GDPR, what is an compatible purpose will be a judgement call from the context of collection.

Re: GDPR – A Practical Guide for Developers (2017)

#55
post #46
post #27

Earlier quoted context omitted.

It looks like the maximum fine is 4% of annual revenue... seems like the regulation has no teeth if you have no revenue. IANAL and could be totally wrong. To your point about small companies, I agree, it feels onerous. What irks me about the right to be forgotten is that it directly counters my right to remember things. Should a shop keeper be allowed to record their observations about who enters their store each day…

Yes, for privacy reasons, it’s not appropriate to keep observations on your fellow citizen...

Dear diary, today I had a discussion on HN with tajen.

Will HN support erasing your comment history if you ask?

Re: GDPR – A Practical Guide for Developers (2017)

#57
post #23

Earlier quoted context omitted.

Don't store a bunch of personally identifiable data and you don't have to do any of this. We have seen what this laissez faire attitude to "capture everything, delete never" has done. Trust has been supremely squandered so at this point I don't think anyone is particularly inclined to believe when someones cries wolf.

The problem is that pretty much everything seems to be considered personally identifiable data. Any web community will at least be storing usernames, passwords, emails and most likely IP addresses. As far as I know, all of that counts. And even if you don't have a login system, your web server is still going to be logging people's IP addresses.

Your webserver logging IP addresses is a legitimate interest that does not require consent (preventing abuse).

I do hope you're not storing passwords, only a securely stretched and hashed variant, which is not subject to the GDPR.

Emails and Usernames will require consent, as do IPs stored outside a context of legitimate interest (preventing abuse).

The only thing that most communities will be missing is a function to delete all user data from their website (ie, delete user + all posts on request) but that should come into standard software soon enough or is already present.

Re: GDPR – A Practical Guide for Developers (2017)

#58

I really don't understand how this is going to work in practice for small side projects with a single part-time developer. How are they supposed to afford implementing all these changes, none of which seem trivial or even practical for your standard little PHP site? So if I run a forum as a side project, what are my options? 1) Spend all free time over the next few months adding these features and neglect any other w…

'I suspect many people will go for (2) and hope this fizzles out the same way the cookie law did.'

I suspect you may be right. http://nocookielaw.com/

Re: GDPR – A Practical Guide for Developers (2017)

#59

Earlier quoted context omitted.

The problem is that pretty much everything seems to be considered personally identifiable data. Any web community will at least be storing usernames, passwords, emails and most likely IP addresses. As far as I know, all of that counts. And even if you don't have a login system, your web server is still going to be logging people's IP addresses.

Passwords are not personal data, and even if they were, you aren't storing them anyway (right?). There's a tricky question around usernames: they're technically not personal data since they aren't necessarily the real name of the user, but the user can choose to use their real name as their username, which is not easy to distinguish in any automated way. You don't need to store IPs

If someone makes a real name username and you don't do anything else about it, you should be fine.

However, if you take that username, look up the user in the real world and send spam without consent you are in deep shit.

It's all about consent of use and for what. The user has implicitly given consent to use their username as a username but nothing else.

Re: GDPR – A Practical Guide for Developers (2017)

#60
post #23

Earlier quoted context omitted.

Don't store a bunch of personally identifiable data and you don't have to do any of this. We have seen what this laissez faire attitude to "capture everything, delete never" has done. Trust has been supremely squandered so at this point I don't think anyone is particularly inclined to believe when someones cries wolf.

The problem is that pretty much everything seems to be considered personally identifiable data. Any web community will at least be storing usernames, passwords, emails and most likely IP addresses. As far as I know, all of that counts. And even if you don't have a login system, your web server is still going to be logging people's IP addresses.

The point about IP addresses and emails makes me wonder what would happen to spammer blacklists. If they're personal information, does that mean services like Stop Forum Spam and Akismet need to remove data when requested, even if it makes life harder for forum admins and community managers? What about those topics you see on admin forums where you're given a giant list of IPs and emails to copy into the ban settings page?
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