4 ms·

The definition of personal information is easy to understand (albeit broad). However, the vagueness seeps in other areas of the regulation. For example, additi

The definition of personal information is easy to understand (albeit broad). However, the vagueness seeps in other areas of the regulation. For example, additional restrictions are in place for “large scale” processing of personal information, yet “large scale” is never defined. Is that hundreds, thousands or millions of records? As the owner of a very small SaaS business (that does not sell personal information of its users) I found it tremendously difficult to figure out how to comply given the vagueness of it all.

midasz 8y ago
Yeah I get that. I googled around a bit and apparently there were concrete figures in the initial draft. I don't know if the EU has a contactperson to whom you can ask these questions, if they do, you can simply ask them to clarify. If you've done that, you're in the clear because you've put in the effort to comply. But yeah in this case they should just give you a number.
- pjc50 8y ago
  > I don't know if the EU has a contactperson to whom you can ask these questions, if they do, you can simply ask them to clarify. lol of course there isn't an office you can ring to help you with this! If there were we wouldn't be spending quite so much effort working out what it all means.
  - M2Ys4U 8y ago
    Each of the 28 member states of the EU has a data protection authority. Those are the people one rings to get advice.
  - midasz 8y ago
    Well for my country (NL) we have the AP and with 2 clicks I have their phone number: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/telefonisch-contact https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-auto... .... > If there were we wouldn't be spending quite so much effort working out what it all means People love drama.
    - repolfx 8y ago
      You don't seem to know much about GDPR. Firstly, no, your national regulators cannot give you binding answers about GDPR. This is one thing the EU Commission has been clear on. They can advise, but their advice has no more weight than this Hacker News thread does - the EU is not required to care about what national regulators said and they have no special powers to interpret the law. Only the EU gets to decide what GDPR means, and they have said explicitly they will not answer questions about it. The only time answers finally come is during legal actions. Secondly, no, people do not "love drama" in the business context, far from it. Maybe you should consider that your own interpretation of the problem is the issue rather than other people just causing drama for the sake of it.
      - midasz 8y ago
        k
jacquesm 8y ago
> For example, additional restrictions are in place for “large scale” processing of personal information, yet “large scale” is never defined. Is that hundreds, thousands or millions of records? Hundreds or thousands not, millions definitely yes, somewhere in the middle you get to draw a line which to me is an indication that the closer you get to those millions the more you'll have to work and then those additional restrictions kick in. There are companies that store billions of profiles (Google, Facebook), and for those the 'large scale' moniker is a no-brainer. If you're a small company that stores a few hundred to a few tens of thousands of records because you are doing direct business with those people then that would most likely still qualify as small. But from 100K and up I'd make sure the house was in order, not just because of the GDPR but because you are becoming a nice, fat & juicy target for miscreants as well.
- tchock23 8y ago
  That is the scope I was ballparking mentally (and which fits the scope of processing done in my app), but I just wish they had been explicit about it in the regulation so I could put to rest any apprehension around it.
  - jacquesm 8y ago
    The room built in is to ensure that there is some flexibility regarding for instance financial and health information where those restrictions would probably kick in sooner versus some e-commerce company such as a web store where the need to keep the data around on live systems is much less urgent. That way one law will allow banks, insurance companies, hospitals and a mid-sized e-commerce company all to figure out for themselves what their comfort zone is, add a little room for safety and you're most likely going to be good, and even if not you can point at the law and say 'it wasn't explicit', so unless you are purposefully mis-interpreting a few million records as 'small scale' you will likely get away with that. Note the 'likely', this isn't a certainty but in my experience to date everybody that is fear mongering about the GDPR is coming up with the wildest of scenarios rather than to just look at the law as if it was intended well (which I really believe it is).

midasz 8y ago

Yeah I get that. I googled around a bit and apparently there were concrete figures in the initial draft. I don't know if the EU has a contactperson to whom you can ask these questions, if they do, you can simply ask them to clarify. If you've done that, you're in the clear because you've put in the effort to comply. But yeah in this case they should just give you a number.

pjc50 8y ago
> I don't know if the EU has a contactperson to whom you can ask these questions, if they do, you can simply ask them to clarify. lol of course there isn't an office you can ring to help you with this! If there were we wouldn't be spending quite so much effort working out what it all means.
- M2Ys4U 8y ago
  Each of the 28 member states of the EU has a data protection authority. Those are the people one rings to get advice.
- midasz 8y ago
  Well for my country (NL) we have the AP and with 2 clicks I have their phone number: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/telefonisch-contact https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-auto... .... > If there were we wouldn't be spending quite so much effort working out what it all means People love drama.
  - repolfx 8y ago
    You don't seem to know much about GDPR. Firstly, no, your national regulators cannot give you binding answers about GDPR. This is one thing the EU Commission has been clear on. They can advise, but their advice has no more weight than this Hacker News thread does - the EU is not required to care about what national regulators said and they have no special powers to interpret the law. Only the EU gets to decide what GDPR means, and they have said explicitly they will not answer questions about it. The only time answers finally come is during legal actions. Secondly, no, people do not "love drama" in the business context, far from it. Maybe you should consider that your own interpretation of the problem is the issue rather than other people just causing drama for the sake of it.
    - midasz 8y ago
      k

jacquesm 8y ago

> For example, additional restrictions are in place for “large scale” processing of personal information, yet “large scale” is never defined. Is that hundreds, thousands or millions of records? Hundreds or thousands not, millions definitely yes, somewhere in the middle you get to draw a line which to me is an indication that the closer you get to those millions the more you'll have to work and then those additional restrictions kick in. There are companies that store billions of profiles (Google, Facebook), and for those the 'large scale' moniker is a no-brainer. If you're a small company that stores a few hundred to a few tens of thousands of records because you are doing direct business with those people then that would most likely still qualify as small. But from 100K and up I'd make sure the house was in order, not just because of the GDPR but because you are becoming a nice, fat & juicy target for miscreants as well.

tchock23 8y ago
That is the scope I was ballparking mentally (and which fits the scope of processing done in my app), but I just wish they had been explicit about it in the regulation so I could put to rest any apprehension around it.
- jacquesm 8y ago
  The room built in is to ensure that there is some flexibility regarding for instance financial and health information where those restrictions would probably kick in sooner versus some e-commerce company such as a web store where the need to keep the data around on live systems is much less urgent. That way one law will allow banks, insurance companies, hospitals and a mid-sized e-commerce company all to figure out for themselves what their comfort zone is, add a little room for safety and you're most likely going to be good, and even if not you can point at the law and say 'it wasn't explicit', so unless you are purposefully mis-interpreting a few million records as 'small scale' you will likely get away with that. Note the 'likely', this isn't a certainty but in my experience to date everybody that is fear mongering about the GDPR is coming up with the wildest of scenarios rather than to just look at the law as if it was intended well (which I really believe it is).