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And "large scale" means how many records in DB? How many users? Or records per day?
by kingofhdds 8y ago
And "large scale" means how many records in DB? How many users? Or records per day?
- pgeorgi 8y agoMonal is an XMPP client running on user's iOS devices. Is that person even running an XMPP server for those users?
- peteretep 8y agoThese are excellent questions that you will have to have shown you've considered if you get audited. If there's disagreement with the regulator, you'll come together to resolve it, and then may need to appoint one.
- kingofhdds 8y agoWell, so it's undefined, at least until practice of legal application establishes. Undefined means risk, and stopping serving EU is a meaningful mitigation, if your profits don't compensate you for all the hassle. Where's "overreaction“ then?
- scotty79 8y agoI guess if you have to ask that question you are not a large scale.
- kingofhdds 8y agoI don't think an argument of such kind would stand in your communication with regulators, or (especially) in courts.
- scotty79 8y agoThis is "what will you do if the lightning strikes you" thinking. Only about less probable things.
- kingofhdds 8y agoI'm not sure I understand your point. Do you mean “they won't catch you"?
- scotty79 8y agoThey won't even manage to precisely decide what actually means 'large' let alone if it applies to you specifically, before you die of old age. The above statement will apply to everybody or nearly everybody (still not you).
- Angostura 8y agoWhy have you isolated one element from a multiple element sentence: If * core activities * require * large scale * regular * systematic If you tick all those other boxes, but are concerned that your processing may be teetering on the boundary of 'large scale', I would be cautious and assume your liable.
- kingofhdds 8y agoAll repeatable processes are systematic, almost the whole IT goes into the category. And "core" is undefined too. I agree that it is safer to imply you're liable.
- caffeine5150 8y agoA UK privacy attorney I know considered 20k records (individuals) to be large scale. I haven't seen much helpful guidance. The WP29 guidance I've read only gives examples at the very extremes of large and small so not too helpful. Practical guidelines will evolve over time.