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I was loose in introducing the word "capture", which blurred the distinction you're making. But the OC seems to be suggesting that IP blocking is likely to be
by evrydayhustling 9y ago
I was loose in introducing the word "capture", which blurred the distinction you're making. But the OC seems to be suggesting that IP blocking is likely to be a one stop solution for someone trying to avoid GDPR details, and your replies leave open that impression.
In fact, there are many ways someone might be profiling without knowing it. For example, precedent about when logging IP addresses constitutes PII is still evolving and seems to apply in cases that would be unintuitive to many US businesses: https://www.whitecase.com/people/tim-hickman https://www.whitecase.com/people/tim-hickman. And there have been arguments that geolocating based on IP might itself be data enrichment that contributes to an argument that you are profiling!
Similarly, I haven't seen a clean interpretation of what constitutes offering (or clearly not offering) services to EU users, which determines application to a data processor. For example, if I offer a Portuguese translation of my site for Brazilian users, have I offered service to continental Portuguese?
IANAL but nobody knows exactly where GDPR will apply yet. I think the better takeaway for someone who is trying to respond with minimum effort is: IP blocking might help you build a defense, but it might matter how you implement it and it might not be sufficient.