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I read the audit, and here's something I noticed (other than that it's 8 years old): "In determining appropriate retention periods for personal information, da

by z3c0 7y ago

I read the audit, and here's something I noticed (other than that it's 8 years old): "In determining appropriate retention periods for personal information, data controllers can have due regard to any statutory obligations to retain data. However, if the purpose for which the information was obtained has ceased and the personal information is no longer required for that purpose, the data must be deleted or disposed of in a secure manner. Full and irrevocable anonymisation would achieve the same objective." (Page 69, under 3.4 Retention) So basically, as long as it's anonymised, the data can be retained.

IggleSniggle 7y ago
But “if the purpose for which the information was obtained” was to enable better ad targeting, then “data retention” is still “appropriate”, eh? Under this reading, is there even an obligation to anonymize? And how anonymous does anonymous need to be? Does a simple base64 encoding count as “anonymized”?
- z3c0 7y ago
  I had that thought originally too - however the keywords here are "statutory obligation" (basically, legal reasons.) So if the FBI asked them to retain the data, they can do so as long as the FBI needs it. And the matter of anonymisation is a great question - "irrevocable" anonymisation certainly has a different meaning back in 2011, when swapping a name for a guid would do the job. Nowadays, it would require at least deleting all relationships as well, since social network analysis is much more advanced these days (especially at FB, of all places.) It wouldn't be impossible to derive the identity of an anonymous account/record based on the undeleted data associated with it. And since FB's "ghost profiles" are something we know exist, I think it's safe to assume those relationships are being maintained somehow.
bigiain 7y ago
<cynical interpretation> The data can be retained so long as Facebook is in the business of targeted advertising, and that's "the purpose for which the information was obtained". Also, I'm now looking forward to Zuck's next apology for "a breach of trust" and his explanation of how they "failed to live up to their own standards" when it becomes publicly undeniable that their "Full and irrevocable anonymisation" of data they've claimed is deleted is as flawed as all the other attempts we've seen of doing that.

by z3c0 7y ago

IggleSniggle 7y ago

But “if the purpose for which the information was obtained” was to enable better ad targeting, then “data retention” is still “appropriate”, eh? Under this reading, is there even an obligation to anonymize? And how anonymous does anonymous need to be? Does a simple base64 encoding count as “anonymized”?

z3c0 7y ago
I had that thought originally too - however the keywords here are "statutory obligation" (basically, legal reasons.) So if the FBI asked them to retain the data, they can do so as long as the FBI needs it. And the matter of anonymisation is a great question - "irrevocable" anonymisation certainly has a different meaning back in 2011, when swapping a name for a guid would do the job. Nowadays, it would require at least deleting all relationships as well, since social network analysis is much more advanced these days (especially at FB, of all places.) It wouldn't be impossible to derive the identity of an anonymous account/record based on the undeleted data associated with it. And since FB's "ghost profiles" are something we know exist, I think it's safe to assume those relationships are being maintained somehow.

bigiain 7y ago

<cynical interpretation> The data can be retained so long as Facebook is in the business of targeted advertising, and that's "the purpose for which the information was obtained". Also, I'm now looking forward to Zuck's next apology for "a breach of trust" and his explanation of how they "failed to live up to their own standards" when it becomes publicly undeniable that their "Full and irrevocable anonymisation" of data they've claimed is deleted is as flawed as all the other attempts we've seen of doing that.