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Google plans to move UK users' accounts outside EU jurisdiction
- jtylr 7y agoPreviously posted and discussed here: https://news.ycombinator.com/item?id=22370405 https://news.ycombinator.com/item?id=22370405
- s_dev 7y agoI would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than trying to deal with the exceptions.
- topbanana 7y agoWhy would that be necessary?
- normalnorm 7y agoBecause unless the UK and the EU reach a trade agreement by the end of the year, the provisions of the Withdrawal Agreement kick in and Northern Ireland becomes bound to EU regulation. This is a long and complicated story, but essentially Brexit created the following problem: the UK now desires to have full control over its borders, and this means a hard border between the UK and the EU. But then there is also the Good Friday Agreement (GFA), which achieved peace between the unionists (Protestants who want NI to be part of the UK) and the nationalists (Catholics who want NI to be part of Ireland). Simplistically, the GFA guarantees a sort of double affiliation of NI, both to the UK and to Ireland. This means, among other things, no physical borders.
- ptah 7y agoi think the stronger data protection would prevail for NI
- s_dev 7y agoI agree, like the California effect in the US. California is both the strictest and biggest car market and all the car manufactuers use California as the standard because it covers everyone else.
- supergarfield 7y ago> British law also N.Irish people to declare themselves Irish under the GFA This by itself doesn't mean anything for GDPR—GDPR applies to EU residents (whether or not they are EU citizens), not EU citizens. Declaring yourself Irish doesn't make you fall under GDPR protection if you live outside the EU.
- tehlike 7y agoI am not sure if this entirely true. My understanding was it was both citizens and residents.
- vageli 7y agoThis link [0] seems to suggest otherwise. [0]: https://www.hipaajournal.com/does-gdpr-apply-to-eu-citizens-living-in-the-us/ https://www.hipaajournal.com/does-gdpr-apply-to-eu-citizens-...
- _-___________-_ 7y agoGDPR applies to EU & EEA residents.
- _-___________-_ 7y agoA fairly readable summary of the territorial scope of GDPR: https://edpb.europa.eu/sites/edpb/files/files/file1/edpb_guidelines_3_2018_territorial_scope_en.pdf https://edpb.europa.eu/sites/edpb/files/files/file1/edpb_gui... In fact, it's not even legal residency that matters. You must simply be present in the territory that the regulations apply to (EU+EEA). If you're not, then the protections don't apply to you, regardless of your citizenship.
- icebraining 7y ago> If you're not, then the protections don't apply to you, regardless of your citizenship. Yes, unless the company is itself in the EU, in which case the GDPR always applies, even if you're not a citizen, resident or even visitor to the EU.
- rwmj 7y agoIt is real. I just got an email about this from Google about my gmail account: - Your service provider and data controller is now Google LLC: Because the UK is leaving the EU, we’ve updated our Terms so that a United States-based company, Google LLC, is now your service provider instead of Google Ireland Limited. Google LLC will also become the data controller responsible for your information and complying with applicable privacy laws. We’re making similar changes to the Terms of Service for YouTube, YouTube Paid Services and Google Play. These changes to our Terms and privacy policy don’t affect your privacy settings or the way that we treat your information (see the privacy policy [link redacted] for details). As a reminder, you can always visit your Google Account < https://myaccount.google.com https://myaccount.google.com > to review your privacy settings and manage how your data is used.
- nightcracker 7y ago> These changes to our Terms and privacy policy don’t affect your privacy settings or the way that we treat your information. This is such a blatant lie what the hell. The only reason for this move is specifically to treat your information in ways that are not legal now.
- dboreham 7y agoNot necessarily. They might treat information the same way but generate different paperwork or have different levels of risk from frivolous lawsuits.
- TheCoelacanth 7y agoAlternate interpretation: it doesn't affect the way they treat your information because they weren't going to follow GDPR anyway.
- duxut_staglatz 7y agoThis is not a lie if these changes do not do anything but later ones will.
- Symbiote 7y ago
- pmlnr 7y agoI don't completely understand what gives them the right to do so - legislation are still in place, GDPR & the rest are included.
- rcMgD2BwE72F 7y agoGDPR only applies to EU residents, doesn't it?
- ollie87 7y agoUK citzens are still EU residents for now, the UK hasn't actually left yet.
- vechagup 7y agoThe EU disagrees: https://europa.eu/european-union/about-eu/countries_en#28members https://europa.eu/european-union/about-eu/countries_en#28mem.... The UK may still be following some of the EU's rules, but they have officially left the union.
- pmlnr 7y agoYeah, the UK didn't fell out of the EU. There's a transition period that just started and right now, there's basically no change yet.
- throwaway237654 7y agoThe UK is planning to leave the EU, so Google is planning to treat UK accounts as not part of the EU. I don't see what is difficult to understand about this.
- Symbiote 7y agoThe word "now". The UK is following EU rules and regulations at least until the end of the year. After that point, it can pick and choose, based on negotiations for trade agreements or whatever other reason pleases it.
- ckastner 7y agoThe optics of this might look bad, but I cannot really fault Google for this move (and I frequently fault Google). They're facing a dilemma of regulatory uncertainty, and this move resolves this dilemma for them (at least, they seem to believe that). Anyone who has ever dealt with powerful regulatory agencies will probably agree that this resolution is the right move for the company, a move important enough that eating some bad PR is probably totally worth it. (The point about powerful regulatory agencies is not that it's hard to stay compliant; it's that the costs, overhead, bureaucracy etc. of demonstrating this compliance is immense, even if you are doing everything 100% right.)
- Zenst 7y agoMight be down to costs. How much does hosting per account in Ireland compare to USA hosting? Even if a few pennies/cents, at google's scale - that makes business sense and if they can, they will.
- unbeli 7y agoThis has nothing to do with the actual location of the servers holding the data. Which would not be a single location anyway.
- Zenst 7y agoActually it does play a factor, GDPR had it so the data on EU citizens had to be located within the EU. Now they have alternative options for the UK - then that aspect does as I initially outlined becomes key. Hence the question of actual costs to Google in hosting in say Ireland (staffing, taxes, rates, utility costs, cooling....) compared with another location outside the EU that may very well have cheaper running costs due to many factors. I hope that clears up why location is a factor now as it related to running costs and if they can save some money, well, they will. More so if they suddenly free up capacity in a datacenter which has higher costs than some other locations outside the EU. All these details do very much, however small, stack up at the scale of users Google operates with and for the UK, several million is a large chunk of potential savings.
- CTn 7y agoWhy Google plans to move UK users' accounts outside EU jurisdiction ?? <a href="https://www.currenttrendnews.com/2020/02/google-plans-to-move-uk-users-accounts.html">See https://www.currenttrendnews.com/2020/02/google-plans-to-mov... it.</a>
- three_seagrass 7y agoDuplicate: https://news.ycombinator.com/item?id=22370405 https://news.ycombinator.com/item?id=22370405
- bananamerica 7y agoI’m sorry, am I on Stack Exchange?
- dang 7y agoOn Hacker News, we're pretty careful about dupes, but for different reasons and in a different way than on SE. Here the issue is that frontpage space is the scarcest resource that HN has (only 30 slots at a time). Since the site exists for intellectual curiosity, and curiosity withers under repetition, it's important not to have those slots taken up by stories that have had a significant recent discussion. (For example, the OP had a major thread yesterday.) Reposts are allowed in the other cases. That is, if a story hasn't had significant attention yet, we don't treat a repost as a dupe. Similarly, if it has had a significant discussion but not recently, it's ok to resubmit it. That's because once enough time has gone by, the topic can gratify curiosity again. The cutoff is a year or so. This is in the FAQ: https://news.ycombinator.com/newsfaq.html https://news.ycombinator.com/newsfaq.html.
- bananamerica 7y agoIt's okay to point out duplicates, it's just odd to see it done in such a spartan manner over here.
- bananamerica 7y agoThanks, Brexit!
- projectramo 7y agoI imagine a future where the workers are on the Irish side of the border but the servers are on the UK side of the border. One still enjoys the tax advantages of the value being added on the Irish side, but also the relatively lax data requirements on the British side. I am not pro or con anything, just pointing out the arb.
- rolltiide 7y agoGoals. I like our role models. I would have never independently perceived most of these opportunities and possibilities. Thank you Google and other multinationals, and the media for dissecting their expensive legal strategies.
- anticensor 7y agoBritain already adopted GDPR-based data protection law. If anything, Brexit will tighten the situation by requiring the data of British to stay in Britain.
- Zenst 7y agoThat certainly is an outcome. Equally does add more credence to the Google move as if the data was in the EU, then the potential to kick up a fuss and roll out laws to insist it is in the UK would play out faster than say that data in the USA. Equally - I'd say costs may well play out more and what is the cost to host in Ireland compared to hosting in the USA? Even when we are talking pennies/cents in difference - at the scale of Google - that soon adds up and if they can, they will.
- CTn 7y agohttps://www.currenttrendnews.com/2020/02/google-plans-to-move-uk-users-accounts.html https://www.currenttrendnews.com/2020/02/google-plans-to-mov...
- i287n 7y agoDoes anyknow what happens if I move out of the UK to rEU? Will my account now be considered to be an EU account or will it always be a UK one?