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It's not just querying and deleting data, though. You have to be able to demonstrate audit trails of consent, including what the user consented to and when. Yo
by cheald 8y ago
It's not just querying and deleting data, though.
You have to be able to demonstrate audit trails of consent, including what the user consented to and when. You have to be able to demonstrate audit trails proving deletion requests. You have to have audit trails of who has ever accessed this data. You have to have a means to exclude pieces of your dataset from aggregate statistics on demand. Also, your audit trails can't contain PII because then your audit trails are in violation of the deletion requests, so you have to have mechanisms of proving that you processed deletion requests without actually identifying the data processed. You're also now obligated to respond to data inquiries in perpetuity, even to people for whom you have no data. Article 32 appears to impose a requirement for encryption at rest, high availability, disaster recovery, and regular penetration testing - all good things, to be sure, but completely impractical for the small hobbyist. Your "querying and deleting" is, by the letter of the law, now required to be a full-blown production-ready architecture with a business's worth of documentation.
And all because you wanted an email address to keep your login form from getting spammed?
I realize that in practicality, this is unlikely to ever be leveraged in any significant scope against most hobbyists, but the law is merciless and it is foolish to assume that you won't be caught in its crosshairs just because you weren't its intended target.
- falcolas 8y ago> And all because you wanted an email address to keep your login form from getting spammed? No, all this because companies were selling your email address to spammers. Also, your reading of the law seems at odds with most other readings I've seen. I'm sure it will come down to a lawyer - but I'm also sure that hobby programmer who take reasonable steps won't ever be in the crosshairs of the EU.