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By this argument, then, should third party requests always be blocked? If the user "is in no position to decide", that means that the only way to avoid potentia
by Spoom 5y ago
By this argument, then, should third party requests always be blocked? If the user "is in no position to decide", that means that the only way to avoid potential liability would be to load everything from the same domain, right? No CDNs, no off-site scripts, no off-site embeds, ever. Seems a bit extreme to me.
Thoughts my own, not those of my employer.
- xg15 5y agoTo my knowledge, there are other avenues beside consent under which the GDPR allows data exchange with third parties - in particular if such an exchange is essential for fulfilling the service. The point here was though, that the data exchange was not "essential" because you could simply self-host the fonts or proxy the request through your own servers. But yes, it would seems to me that this interpretation of the law sort of communicates that third party requests should be a measure of last resort. That would definitely cause a shift in current web dev practices, but I'm not sure it's a bad thing. > avoid potential liability I think "potential" liability is an odd criterion. Any law is a risk of potential liability. If the effort to find out if a law actually applies to you is already too much, then I guess anything less than anarcho-capitalism would be unacceptable.
- Spoom 5y ago> self-host the fonts Do you, as the website operator, have the right to copy and serve these fonts to your visitors? (Actual question; my guess is that you don't according to Google Fonts, but could be wrong.) > proxy the request through your own servers Isn't this worse? Assume that your visitor does not want Google contacted at all as part of their visit; isn't, then, the potential leak of an IP address simply a side effect? The website is still leaking timing of when a visitor accessed the site, potentially their usage patterns... Personally, I think this is a bit of an absurd argument... I think, at most, consent should be enough for third party requests. I was mostly responding to GP's claim that the user can't reasonably consent to such use.
- latk 5y ago> Do you, as the website operator, have the right to copy and serve these fonts to your visitors? All the fonts on Google Fonts are open source. When GDPR came into force in 2018 I downloaded all the fonts I needed, checked their licenses, and uploaded them on my servers along with necessary notices as required by the licenses. The matter could also be sidestepped if the CDN were to offer a GDPR data processing agreement (DPA) and would make guarantees about the locations of servers. The free public CDNs understandably don't do this, and it seems Google Fonts is not covered by the Google Cloud DPA.
- xg15 5y ago> Do you, as the website operator, have the right to copy and serve these fonts to your visitors? Good question. I have no idea, but apparently the court thinks self-hosting is ok in this case. > Isn't this worse? Assume that your visitor does not want Google contacted at all as part of their visit; isn't, then, the potential leak of an IP address simply a side effect? The website is still leaking timing of when a visitor accessed the site, potentially their usage patterns... There is a specific set of data which is defined as "personally identifiable information". IP address is part of that set, but I don't think timing information or anonymous usage data are. So the question in this case is specifically "does the request leak information defined as PII?". You can prevent that effectively with proxying: Google would only see the IP address of your proxy but not the address of the user. > Assume that your visitor does not want Google contacted at all as part of their visit I don't think a user can enforce this under the GDPR. They only have a right to block you from sending their PII to Google, not to block you from talking to Google at all.
- DavyJone 5y ago> There is a specific set of data which is defined as "personally identifiable information". I believe there isn't and that is part of the problem with GDPR in my experience.