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GDPR for lazy people: Block all European users with Cloudflare Workers

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Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#901
post #573

Earlier quoted context omitted.

Merely setting a delete flag is not compliant with the GDPR, that's why a cascading delete is necessary. Any programmer worth their salt knows mass random deletes and updates are extremely inefficient.

Wouldn't it be possible to just delete the 'idetifiabel' parts in the database in order to be GDPR compliant? If you for instance save all the user data like user preferences under a random userId, and then delete the personal data (such as email address, name etc.) associated with the userId I would expect this to be GDPR complaint without having to do a cascading delete.

This may well be harder to get right than just deleting the data. Just as in the saying (and this is a terrible paraphrase) goes:

  "Anyone can design a lock that they themselves can't pick"
If you think you have anonymised data sufficiently you may well not have done it sufficiently to prevent others from re-conctructing it:

https://en.wikipedia.org/wiki/AOL_search_data_leak

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#902

I’ve been reading hacker news for about a decade, and it’s getting to the point where I don’t think there are many entrepreneurs and/or technical people on here anymore. The number of people who are saying it’s no big deal to comply with this huge law, especially for very small startups, is mind boggling. Let’s just take one feature: the requirement that you can permanently delete all of your information. Most early-…

Yep. Doing a one person startup (in the US) I absolutely do not have time (or money) to mess around trying to figure out GPDR compliance. I'm not selling data to anyone, and I'm not collecting anything beyond an email address during sign-ups at this point, in any case. If a user decides they want to store PII or other sensitive data on my system, I can't stop them, but I'm not going to go combing through their data in order to sell it either. Most likely I'm just going to have to avoid doing business with Europe for the time being.

A quick read of some of the provisions of GPDR immediately brought to mind this passage from Atlas Shrugged:

> “Did you really think we want those laws observed?" said Dr. Ferris. "We want them to be broken. You'd better get it straight that it's not a bunch of boy scouts you're up against... We're after power and we mean it... There's no way to rule innocent men. The only power any government has is the power to crack down on criminals. Well, when there aren't enough criminals one makes them. One declares so many things to be a crime that it becomes impossible for men to live without breaking laws. Who wants a nation of law-abiding citizens? What's there in that for anyone? But just pass the kind of laws that can neither be observed nor enforced or objectively interpreted – and you create a nation of law-breakers – and then you cash in on guilt. Now that's the system, Mr. Reardon, that's the game, and once you understand it, you'll be much easier to deal with.”

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#903
post #519

Earlier quoted context omitted.

> Someone says "delete me and my purchases", so you do, and oops - total book sales are now wrong. Erase the name and address fields from the user in the database. You don’t have to delete any line, and that person doesn’t have any personal info in your database anymore. Problem solved.

Two days later the customer files a chargeback with their credit card company and the credit card company wants you to provide documentation for the transaction.

IF my understanding is correct, you can actually keep a denormalized version of user information (name, shipping info etc) and still be compliant, assuming you do not use that billing information for any purpose other than billing.

The "right to erasure" isn't as strict as the "right to be forgotten" -- You (the end-user) would need to prove that merely having your name and address in billing records violates your right to privacy. And to make that argument you'd have to provide evidence the business is using said information for purposes other than billing.

Personal data can be used lawfully to "fulfill contractual obligations with a data subject" (eg: fulfilling a purchase, and retaining information for warranty/returns/RMA etc purposes) and "To perform tasks at the request of a data subject who is in the process of entering into a contract with the controller. " and "For the legitimate interests of a data controller or a third party"

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#904
post #895

I’ve been reading hacker news for about a decade, and it’s getting to the point where I don’t think there are many entrepreneurs and/or technical people on here anymore. The number of people who are saying it’s no big deal to comply with this huge law, especially for very small startups, is mind boggling. Let’s just take one feature: the requirement that you can permanently delete all of your information. Most early-…

> Most early-stage startups use the (in 2008, when I did mine) best practice of “delete=1”. Changing your whole database over to permanent cascade delete is only easy if you’re a very experienced programmer or who knows what he’s doing. HAHAHAHAHAHAHAHAHAHAHAHAHAHAAHA How did you get upvoted so much

I assume it is your tone getting you down voted, but the message is true. If a cascading delete is too hard for someone building the tech at a startup, it's no wonder emails and passwords are leaked every single day.

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#905

I’ve been reading hacker news for about a decade, and it’s getting to the point where I don’t think there are many entrepreneurs and/or technical people on here anymore. The number of people who are saying it’s no big deal to comply with this huge law, especially for very small startups, is mind boggling. Let’s just take one feature: the requirement that you can permanently delete all of your information. Most early-…

> Let’s just take one feature: the requirement that you can permanently delete all of your information.

Let's take that feature because it's mentioned often, but it doesn't exist.

Read Article 17* carefully yourself. It doesn't say "permanent". It never even says the word "delete". Elementary, My Dear Watson.

* https://gdpr-info.eu/art-17-gdpr/

> at an early stage startup with one programmer, you cannot have that one programmer spending two months on compliance.

And then here's the other straw man.

An early stage startup in the US with one programmer has more to worry about from US regulation than European regulation. Nonetheless, if you want to trade with Europe then reading the ICO guidance on the GDPR for your business should take a couple of hours.

> My biggest fear is that all of these complex bureaucratic laws are just raising the bar for doing a startup.

There are so many things I care about more than whether you can create a startup with wilful disregard for people's rights.

Did you even notice that Equifax* lost control of personal data on pretty much every single American? Your name, date of birth, your SSN. Equifax did this because they are actually incentivised to make their systems as insecure as they can get away with.

The only thing you're right about is that real security has real costs, but you're not convincing me that they're not needed.

* https://www.sec.gov/Archives/edgar/data/33185/00011931251815...

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#906

I’ve been reading hacker news for about a decade, and it’s getting to the point where I don’t think there are many entrepreneurs and/or technical people on here anymore. The number of people who are saying it’s no big deal to comply with this huge law, especially for very small startups, is mind boggling. Let’s just take one feature: the requirement that you can permanently delete all of your information. Most early-…

First off, the GDPR just harmonizes existing data protection laws, and increases the associated penalties to give those laws teeth. If you need to do something fundamentally new today, you probably broke these laws yesterday already. Stop whining because you feel forced to comply now, just due to the fines having been increased. That's a basic risk of entrepeneurship.

Next, something like the deletion right has to submit to other laws that mandate data retention, like having to keep sales and bookings records for 10 years due to tax laws. If you do a cascading deletion in your data set, you're probably breaking these, so flagging records as deleted, or moving them to an archive to comply with these other laws still is perfectly find.

So this is just another regulation a startup has to think about. It's way easier than, i.e., tax laws, so please. Just stop panicking -.-

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#907

I’ve been reading hacker news for about a decade, and it’s getting to the point where I don’t think there are many entrepreneurs and/or technical people on here anymore. The number of people who are saying it’s no big deal to comply with this huge law, especially for very small startups, is mind boggling. Let’s just take one feature: the requirement that you can permanently delete all of your information. Most early-…

Thank you for saying this, another thing that is ridiculously difficult is to delete specific user from all your backups. This is made even worse if you have multi region backups and cold back ups. Even a one-year-old start up could have literally thousands of database dumps in different places if they followed best practice of triple redundant daily dumps.

> Thank you for saying this, another thing that is ridiculously difficult is to delete specific user from all your backups.

You have to do very little if you're keeping backups for less than month, simply delete from the DB and wait for backups to age out:

https://ico.org.uk/for-organisations/guide-to-the-general-da...

If you are keeping for longer than a month be prepared to justify that.

> This is made even worse if you have multi region backups and cold back ups.

You should be automating this. I assume you're automating the dumps. Automate the deletion. Deleting three encrypted files off S3 every day really isn't particularly hard. I've written stuff to do this a bunch of times.

> Even a one-year-old start up could have literally thousands of database dumps in different places if they followed best practice of triple redundant daily dumps.

If you have backups sprinkled willy-nilly about the place that you may have lost track of then it shows you have a significant lack of care about my data, and so I don't want you to have it at all.

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#908
post #497

Earlier quoted context omitted.

> Most early-stage startup use the best practice of “delete=1” Honestly that's a bad best practice if the data your collecting is sensitive, which PII is.

It's not so easy. Someone buys a book. Transaction is recorded, and now we know total book sales. Someone says "delete me and my purchases", so you do, and oops - total book sales are now wrong. There's ways around it, obviously. But they are not easy. Much easier to just mark as deleted. Another example: Threaded conversation - someone deletes their post, and oops all the replies are now orphaned.

update books set total_sales = total_sales+1;

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#909
post #244
post #53

I keep seeing these posts on how to block European users to avoid the GDPR. As a citizen of Europe, seeing these posts consistently making it to the front page is disappointing. It would seem that Silicon Valley perceives the GDPR as more of a hindrance than an opportunity to offer users better privacy. Nothing has been learned.

I feel the EU regulators could stand to learn something. If EU citizens are small portion of your users, and your tasked with parsing this document http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX... just blocking them doesn't seem like that bad of an idea, especially with the fines involved. I think the things that bother me is: 1) A College student working on a side project with no revenue are treated t…

> I think the things that bother me is:

>

> 1) A College student working on a side project with no revenue are treated the same as some massive multi-national.

That's false. The GDPR repeatedly refers to evaluating the risk with regards to various decisions. The ICO even has separate guidance for small businesses and big businesses.

> 2) It's a foreign requirement that feels like a violation of sovereignty. Most business/startup owners complain about there being too much domestic regulations, now we have to worry about things outside of our own countries -- that also can come into conflict with our domestic tax authorities on things like data retention. An international agreement would be entirely different.

This one I can appreciate, but perhaps look at it from our point of view:

You're violating our laws that protect our citizens.

Why would we possibly have any sympathy for that?

> 3) The GDPR requires clear and concise language, but have done nothing of the sort when writing the regulations. For most websites outside of the EU, could they not have produced a concise 1-2 page infographic produced by the regulators themselves?

The GDPR is easier to read than many US laws, and you don't have to read it anyway. The ICO has written extremely high-quality guidance for most businesses which will suffice. It should take no more than a few hours to determine how your business would be affected.

https://ico.org.uk/for-organisations/business/

Re: GDPR for lazy people: Block all European users with Cloudflare Workers

#910

Earlier quoted context omitted.

Someone says "delete me and my purchases", so you do In many cases, that will be your mistake. The right to erasure is not absolute, and if you need to keep those records for a good reason -- for example, as evidence to support tax returns or defend chargebacks -- then you are entitled to refuse to delete them and to continue processing them for the necessary purposes. Otherwise mortgages would suddenly become a very…

Great, so now we get to spend money on lawyers and time in the courts to decide what information falls under “OK to keep for a good reason”

No, if you say you need the information for tax purposes (say) then the user will complain to the data protection authorities. These authorities will then accept or reject the complaint, and if accepted will help you to come into compliance.
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