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> an unscrupulous server operator could log the daily key and use it to recover the original data from hashed IDs. > The flaw in this approach is that it still
by openplatypus 4y ago
> an unscrupulous server operator could log the daily key and use it to recover the original data from hashed IDs.
> The flaw in this approach is that it still hinges on identifying data. While it serves as a good compliance and security measure, it doesn't alter anything significant from GDPR's standpoint. The same applies to competitive solutions like Plausible or Fathom.
This is where the technical compliance meets legal compliance. There is always a risk of breach and malicious actors circumventing even the most advanced technical solutions.
It is not full proof, but having SIGNED Data Processing Agreement can go a long way in case of such a violation. It won't help with technical lapses, but can save your business, by pointing at the legal obligation of your data processor for them to take some heat.
Having a partner from a country with a compatible legal system helps a lot in the execution of such an agreement. We no longer deal with non-EU/EEA entities and avoid anyone who uses US-cloud for data processing. The risk is just not worth it. Not to mention, this simplifies Transfer Impact Assessment.