4 ms·

Honestly... none of the questions in this letter are that hard to answer. I really don’t see what the fuss is about if you run a semi-professional operation.

x0x0 9y ago
Then you haven't thought it through or don't understand the gdpr. Though this letter doesn't mention it, you not only have to provide all data in your systems -- every single db inside your company -- but also data from every 3rd party system. Your transactional emailer, your marketing emailer, your billing system, your logging system, your retargeting system, etc.
- avianlyric 9y ago
  That’s not totally true. GDPR only applies if the data is stored in an “filing system”. Things like logs almost certainly don’t fall under that. (Unless you where feeding them into a data mining system, that would change things)
  - dominotw 9y ago
    Are you sure about logs? Kafka is in scope afaik.
    - Someone 9y ago
      I think so, too. Certainly, they should be in scope for the “data protection” part, or (extreme example) you would be allowed to log personal data to a publicly visible server.
      - avianlyric 9y ago
        To be clear, when I say GDPR doesn’t apply. I’m taking about information requests (the topic of the linked article). The data protection part of GDPR of course applies to all PII regardless of how it’s stored. But that part is not new in GDPR, the EU has had strong data protection laws for a while. (Even if people didn’t talk about it)
  - x0x0 9y ago
    Believe whatever you want but (1) our lawyers disagree; (2) if you can query your logs, you have to (PS: you can; that's literally the point of things like sumologic); (3) the various privacy orgs that have published reasonable amounts of guidance -- notably ICO and DPC -- disagree.
  - web007 9y ago
    If you ever log an email address then logs contain PII, and are therefore in scope.
    - r00fus 9y ago
      So why not log just username or transaction id?
      - sobani 9y ago
        Because usernames are PII under de GDPR too.
        r00fus 9y ago
        True, but hidden IDs like the row GUID of the user are not, are they? They should be considered more like pseudonymous data[1] as they're meaningless outside the dataset. [1] https://www.whitecase.com/publications/article/chapter-5-key-definitions-unlocking-eu-general-data-protection-regulation https://www.whitecase.com/publications/article/chapter-5-key...
- jodrellblank 9y ago
  Good. Stop casually aerosolizing information about your customers all over the cloud, and ignoring employees casually copying live databases here there and everywhere.

x0x0 9y ago

Then you haven't thought it through or don't understand the gdpr. Though this letter doesn't mention it, you not only have to provide all data in your systems -- every single db inside your company -- but also data from every 3rd party system. Your transactional emailer, your marketing emailer, your billing system, your logging system, your retargeting system, etc.

avianlyric 9y ago
That’s not totally true. GDPR only applies if the data is stored in an “filing system”. Things like logs almost certainly don’t fall under that. (Unless you where feeding them into a data mining system, that would change things)
- dominotw 9y ago
  Are you sure about logs? Kafka is in scope afaik.
  - Someone 9y ago
    I think so, too. Certainly, they should be in scope for the “data protection” part, or (extreme example) you would be allowed to log personal data to a publicly visible server.
    - avianlyric 9y ago
      To be clear, when I say GDPR doesn’t apply. I’m taking about information requests (the topic of the linked article). The data protection part of GDPR of course applies to all PII regardless of how it’s stored. But that part is not new in GDPR, the EU has had strong data protection laws for a while. (Even if people didn’t talk about it)
- x0x0 9y ago
  Believe whatever you want but (1) our lawyers disagree; (2) if you can query your logs, you have to (PS: you can; that's literally the point of things like sumologic); (3) the various privacy orgs that have published reasonable amounts of guidance -- notably ICO and DPC -- disagree.
- web007 9y ago
  If you ever log an email address then logs contain PII, and are therefore in scope.
  - r00fus 9y ago
    So why not log just username or transaction id?
    - sobani 9y ago
      Because usernames are PII under de GDPR too.
      - r00fus 9y ago
        True, but hidden IDs like the row GUID of the user are not, are they? They should be considered more like pseudonymous data[1] as they're meaningless outside the dataset. [1] https://www.whitecase.com/publications/article/chapter-5-key-definitions-unlocking-eu-general-data-protection-regulation https://www.whitecase.com/publications/article/chapter-5-key...
jodrellblank 9y ago
Good. Stop casually aerosolizing information about your customers all over the cloud, and ignoring employees casually copying live databases here there and everywhere.