3 ms·
Maybe this is not important in your user-case, but what if you have a database breach and you have to warm your users?
by RobertoG 6y ago
Maybe this is not important in your user-case, but what if you have a database breach and you have to warm your users?
- medecau 6y agoArticle 34.3.a seems to disavow the data processor of such requirement. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met: (a) the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption; https://gdpr-info.eu/art-34-gdpr/ https://gdpr-info.eu/art-34-gdpr/
- SahAssar 6y agoI don't think hashing and encryption are considered equivalent in this case.
- GoblinSlayer 6y ago>(c) it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.
- jlcummings 6y agoSo far I haven’t seen a comment point this out or suggest similar, so let’s say that instead of trying to maintain an application level list of email addresses that is used in a breach (or for other reasons), rely on the exercising service (email) which by formerly sending a verification email, has a record of the destination at least in a log, and maybe during registration placed in a “verified member” list, all more or less managed within the mail service.