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The amount of EU companies following this law is exactly 0.
by LunaSea 4y ago
The amount of EU companies following this law is exactly 0.
- deleted 4y ago[deleted]
- exac 4y agoI know I've personally spent a large portion of my time updating systems to be compliant in the last few years, in North American companies.
- mro_name 4y agomight well have been yak shaving. If a company is under US jurisdiction it simply cannot comply to EU data protection.
- deleted 4y ago[deleted]
- mananaysiempre 4y ago... Are those North American companies prepared to willingly break EU laws then? Because in my (amateur) understanding it’s logically impossible to satisfy both CLOUD Act requirements and EU data protection ones (not just GDPR, but general due-process rights the CJEU considers required for privacy violations and US courts deny noncitizens).
- mike_d 4y agoYes. Whenever a US law and a foreign law conflict, the US law always wins when you are in the United States. Complying with US laws is also a perfectly valid defense if a European citizen or state ends up bringing action against you in a US court.
- LunaSea 4y agoEuropean states simply sue in their own territory or in front of the European Union Court of Justice.
- mike_d 4y agoYup. Which is basically a no-op. You need a court having jurisdiction over the defendant to have any relief. Even if you receive a financial judgement, international law does not put much weight in absentia cases.
- LunaSea 4y agoIf you have customers in the EU than the court has jurisdiction. If the company doesn't comply, fines will be directly taken from customer payments for example.
- mike_d 4y agoAgain - regardless of if a domestic court believes they have jurisdiction, any court case not brought in the venue of the defendant is effectively meaningless as you cannot be granted meaningful relief. If the destination bank account is outside the EU, they can't touch it without cooperation from the defendant countries courts - which requires you to file in the defendants venue. If an EU country unilaterally seized intra-bank remittance they would be cut off from the international banking system without hesitation. You seem to really be grasping at straws here, but the EU is not some all powerful entity that can enforce its laws outside its jurisdiction.
- LunaSea 4y ago> Again - regardless of if a domestic court believes they have jurisdiction, any court case not brought in the venue of the defendant is effectively meaningless as you cannot be granted meaningful relief. Of course you can, you simply reach for assets within the border of said member country or the EU. As I mentioned in my previous comment, you can for example get the funds from outgoing payments by customers of said company. You can also freeze accounts, prevent ownership or investments by any citizen of that country as well. > If the destination bank account is outside the EU, they can't touch it without cooperation from the defendant countries courts - which requires you to file in the defendants venue. If an EU country unilaterally seized intra-bank remittance they would be cut off from the international banking system without hesitation. There is nothing unilateral about a country seising money as payment of a fine from a company. This is a standard tool that every countries' IRS equivalent agency have in their tool belt. > You seem to really be grasping at straws here, but the EU is not some all powerful entity that can enforce its laws outside its jurisdiction. I never said that EU is all powerful, however, if business is done within the EU, EU countries have the power to access any and all funds going to the US for companies that do not comply. They can also decide to block said service as a punitive measure.
- speedgoose 4y agoIt’s not true. I know people who lost contracts because they were using Azure and the customer wanted to respect the law.
- LunaSea 4y agoI've talked with companies like that as well and they start with strict rules and end up allowing clouds because no solution is compliant anyway.
- speedgoose 4y agoI guess it works when you don't have any compliant competitor.
- LunaSea 4y agoThat is exactly the problem at hand. It's a combination of low to no enforcement, competitivity-killing laws and unrealistic efforts for said companies to take on.
- fmajid 4y agoHetzner or OVH would be compliant.
- LunaSea 4y agoThey are however far from service parity with AWS, Azure and GCP. I can't speak for Hetzner but OVH has also availability issues.
- di4na 4y agoYep. The real question is how long until we get one. Scaleway seems to go in the right direction but still a bit of work needed
- pjmlp 4y agoI can attest that there are a lot more than zero in Germany.
- LunaSea 4y agoI would be glad to be shown a company with AWS, Google Chrome, Google Search, Slack and all the usual suspects.
- huijzer 4y agoPlease tell the legal department of our uni. I’m stuck with a home-made Kubernetes cluster where I have to mail the admins for provisioning, SSL and domain management. Would love to switch to Fly or Render
- e12e 4y agoThis simply isn't true. At least not for EEC(Norway).
- LunaSea 4y agoI have never seen a company without Google Search, Google Chrome, AWS, Microsoft 360 and the lot. Which alternatives are they based on?
- fcantournet 4y agoThose would not contain PII from your users though, unless you have terrible policies about copying personal information in random Google Docs.
- xorcist 4y agoDefense and government is a huge sector. You can live very well off it. They are not going to skimp on the rules. A large part of banking won't, either.