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I'm using a salted hash to calculate unique visitors. The cleartext IP is never captured or stored and is only available because it's required to return a respo

I'm using a salted hash to calculate unique visitors. The cleartext IP is never captured or stored and is only available because it's required to return a response. What is the right amount of information to share? Most users won't care but others will. I want to simplify rather than complicate. Finding balance is difficult.

closewith 4y ago
> I'm using a salted hash to calculate unique visitors. Where do you store the salted hash?
- shanebellone 4y ago
  The salted hash is stored in a database.
  - closewith 4y ago
    Where is it stored on the client? Or is it a salted hash of the IP address used to connect? If so, the recent precedent from CNIL wouldn't consider that exempt from GDPR cookie banner unless obscured via a first-party proxy.
    - shanebellone 4y ago
      It's the salted hash of the IP used to connect. I did build my approach around the Internet's backbone to future proof. Banning my approach would fundamentally break the Internet. I've made a note and will read into the precedent. Thank you for the research topic.
      - closewith 4y ago
        > Banning my approach would fundamentally break the Internet. That’s simply false. The legal basis for processing an IP address in order to serve an HTTP request in the EU is Art 6 (b): > processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; This does not give you the right to use that data for any other purpose. The approach you’re using is called fingerprinting in the industry (relatively naive fingerprinting given it only uses IP address) and it is the ongoing subject of enforcement action in the EU. Nothing about the approach is compliant. Frankly, if it was this easy to forgo the regulatory impact of the GDPR, every analytics service would do it (many shady ones do).
        shanebellone 4y ago
        Pathview does not fingerprint. Full stop. The salted hash (of the IP address) is used for one purpose: to count unique visits.
        closewith 4y ago
        To associate individual page views to a single real IP address. That is fingerprinting.
        shanebellone 4y ago
        Pathview does not associate individual page views to single real IP addresses.
        closewith 4y ago
        Quite honestly, you are not competent to make that determination. For the purposes of compliance with the GDPR, Pathview does associate individual page views with a single real IP address. From the precedent set by the CNIL ruling on Google Analytics in July, the only way for an analytics tool not to process personal data in the form of an IP address is to relay the request via a first-party proxy (and strip the referer). Your analytics tool cannot accept HTTP requests from the users browser and be compliant with the GDPR without gaining consent. Serving an HTTP request made for the purposes of analytics is processing personal data and there's no legal basis for the processing without consent. > The fundamental problem that prevents these measures from addressing the issue of access of data by non-European authorities is that of direct contact, via an HTTPS connection, between the individual's terminal and servers managed by Google. > The resulting requests allow these servers to obtain the IP address of the Internet user as well as a lot of information about his terminal. This information may realistically allow the user to be re-identified and, consequently, to access his or her browsing on all sites using Google Analytics. > Only solutions allowing to break this contact between the terminal and the server can address this issue. Beyond the case of Google Analytics, this type of solution could also make it possible to reconcile the use of other analytics tools with the GDPR rules on data transfer. Source: https://www.cnil.fr/en/google-analytics-and-data-transfers-how-make-your-analytics-tool-compliant-gdpr https://www.cnil.fr/en/google-analytics-and-data-transfers-h...
njitram 4y ago
I think most people (including me) are looking for how it works to check if it really is (somewhat) GDPR compliant, so for example you want to know if data is stored in aggregate or also individual data (which would fall under GDPR), if individual users are tracked with some kind of identifier, how fast the identifier is deleted, if its stored in disk or only in memory, who can access the identifier, is the identifier pseudonized etc.
- shanebellone 4y ago
  I'm happy to answer any question about what data is acquired and how it is acquired. I cannot answer every question about how my system processes the data. I built a novel algorithm that represents economic leverage. Each hit is stored without personal data but including a salted hash representing the IP. Users are not tracked and are not assigned any type of individual identifier.
  - t0mas88 4y ago
    OK, that's what I was looking for. Storing hits with any kind of identifier is considered processing of personal data under GDPR. It doesn't matter whether you have assigned the identifier or whether you use one that the user already has (IP, device ID etc). Hashing / salting the identifier does not change that if it's still unique. The way to make it compliant is to ask permission for using the data. Or doing your analysis without any user identifiers, but that doesn't get you much useful insights.
    - shanebellone 4y ago
      To be clear, I need to count unique visits without using a salted IP address even when it cannot be attributed to an individual or used to track them across multiple websites? I do have an idea that might work for this scenario. If I can calculate unique visits differently, I can drop the salted hash from the database too. I'm guessing that should be sufficient to satisfy most privacy conscious users.
      - 4y ago

closewith 4y ago

> I'm using a salted hash to calculate unique visitors. Where do you store the salted hash?

shanebellone 4y ago
The salted hash is stored in a database.
- closewith 4y ago
  Where is it stored on the client? Or is it a salted hash of the IP address used to connect? If so, the recent precedent from CNIL wouldn't consider that exempt from GDPR cookie banner unless obscured via a first-party proxy.
  - shanebellone 4y ago
    It's the salted hash of the IP used to connect. I did build my approach around the Internet's backbone to future proof. Banning my approach would fundamentally break the Internet. I've made a note and will read into the precedent. Thank you for the research topic.
    - closewith 4y ago
      > Banning my approach would fundamentally break the Internet. That’s simply false. The legal basis for processing an IP address in order to serve an HTTP request in the EU is Art 6 (b): > processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; This does not give you the right to use that data for any other purpose. The approach you’re using is called fingerprinting in the industry (relatively naive fingerprinting given it only uses IP address) and it is the ongoing subject of enforcement action in the EU. Nothing about the approach is compliant. Frankly, if it was this easy to forgo the regulatory impact of the GDPR, every analytics service would do it (many shady ones do).
      - shanebellone 4y ago
        Pathview does not fingerprint. Full stop. The salted hash (of the IP address) is used for one purpose: to count unique visits.
        closewith 4y ago
        To associate individual page views to a single real IP address. That is fingerprinting.
        shanebellone 4y ago
        Pathview does not associate individual page views to single real IP addresses.
        closewith 4y ago
        Quite honestly, you are not competent to make that determination. For the purposes of compliance with the GDPR, Pathview does associate individual page views with a single real IP address. From the precedent set by the CNIL ruling on Google Analytics in July, the only way for an analytics tool not to process personal data in the form of an IP address is to relay the request via a first-party proxy (and strip the referer). Your analytics tool cannot accept HTTP requests from the users browser and be compliant with the GDPR without gaining consent. Serving an HTTP request made for the purposes of analytics is processing personal data and there's no legal basis for the processing without consent. > The fundamental problem that prevents these measures from addressing the issue of access of data by non-European authorities is that of direct contact, via an HTTPS connection, between the individual's terminal and servers managed by Google. > The resulting requests allow these servers to obtain the IP address of the Internet user as well as a lot of information about his terminal. This information may realistically allow the user to be re-identified and, consequently, to access his or her browsing on all sites using Google Analytics. > Only solutions allowing to break this contact between the terminal and the server can address this issue. Beyond the case of Google Analytics, this type of solution could also make it possible to reconcile the use of other analytics tools with the GDPR rules on data transfer. Source: https://www.cnil.fr/en/google-analytics-and-data-transfers-how-make-your-analytics-tool-compliant-gdpr https://www.cnil.fr/en/google-analytics-and-data-transfers-h...

njitram 4y ago

I think most people (including me) are looking for how it works to check if it really is (somewhat) GDPR compliant, so for example you want to know if data is stored in aggregate or also individual data (which would fall under GDPR), if individual users are tracked with some kind of identifier, how fast the identifier is deleted, if its stored in disk or only in memory, who can access the identifier, is the identifier pseudonized etc.

shanebellone 4y ago
I'm happy to answer any question about what data is acquired and how it is acquired. I cannot answer every question about how my system processes the data. I built a novel algorithm that represents economic leverage. Each hit is stored without personal data but including a salted hash representing the IP. Users are not tracked and are not assigned any type of individual identifier.
- t0mas88 4y ago
  OK, that's what I was looking for. Storing hits with any kind of identifier is considered processing of personal data under GDPR. It doesn't matter whether you have assigned the identifier or whether you use one that the user already has (IP, device ID etc). Hashing / salting the identifier does not change that if it's still unique. The way to make it compliant is to ask permission for using the data. Or doing your analysis without any user identifiers, but that doesn't get you much useful insights.
  - shanebellone 4y ago
    To be clear, I need to count unique visits without using a salted IP address even when it cannot be attributed to an individual or used to track them across multiple websites? I do have an idea that might work for this scenario. If I can calculate unique visits differently, I can drop the salted hash from the database too. I'm guessing that should be sufficient to satisfy most privacy conscious users.
    - 4y ago