4 ms·
Many jurisdictions, including EU, China, and others, require data on their citizens to be hosted locally.
by sroussey 2y ago
Many jurisdictions, including EU, China, and others, require data on their citizens to be hosted locally.
- acedTrex 2y agoThen it would be up to those countries to block traffic to said social media companies. This is what china already does.
- tankenmate 2y agoNot just block traffic, but also any payments.
- throwawayk7h 2y agowhat would happen if a US company, with US servers, ignored those requirements?
- Teocali 2y agoIt would blocked in the EU. Also the company could be asked to forbid EU customer to access the product. Wouldn’t be a big threat but it would prevent the company to do any futur business in Europe. Tech savvy customer could still access the product but that is not a market as big as every EU potential customer.
- HPsquared 2y agoI propose "Net Curtain" as the name for EU's version of the Great Firewall.
- Buttons840 2y agoCopper Curtain
- marcosdumay 2y agoEither Silicon or Optical Fiber Curtain.
- zo1 2y agoA reference to "The Iron Curtain"?
- HPsquared 2y agoIndeed. Like the Iron Curtain, but more porous and networky.
- troupo 2y agoYou truly believe the US wouldn't do the same? BTW what's your take on US requiring US-based companies to provide data on foreign citizens if subpoenaed?
- immibis 2y agoThe US does it through a private business (Cloudflare), so it's constitutional.
- troupo 2y agoI'm desperately trying to figure out this response, and I can't. Meanwhile: https://news.ycombinator.com/item?id=41280221 https://news.ycombinator.com/item?id=41280221
- cscurmudgeon 2y agoThe debate is what EU would do if foreign companies don't obey EU's laws. The debate is not whether the US will do something draconian the EU is doing today.
- troupo 2y agoWhat draconian laws does EU apply to foreign companies? Try to come up with examples of companies that don't have offices and legal and commercial presence in the EU. BTW remind me what's your take on the US banning Huawei in the US?
- BlueTemplar 2y agoSince when do they bother with subpoenas ? Or are you referring to the secret courts rubberstamping wiretapping after the fact ?
- troupo 2y agoI used subpoena as an umbrella term, there are multiple ways to get that data. E.g. here's Facebook's report: https://transparency.meta.com/reports/government-data-requests/country/US/ https://transparency.meta.com/reports/government-data-reques... In July-January 2023 they received FISA requests targeting over 150 thousand foreign nationals
- sigzero 2y agoOr it could cause the actual citizens of the EU to put a stop to the stupidity.
- stickfigure 2y agoI will believe this when I hear about websites being blocked over missing cookie banners.
- Teocali 2y agoYou need to lodge a complaint. It’s time consuming so almost nobody do it. And generally, it came with a slap of the wrist, and the company put up the banner. For a site to be blocked, it need repeatable, multiple and not correctibles infractions.
- stickfigure 2y agoHas it ever happened, even once? Can you cite something? I'm genuinely curious. Also genuinely skeptical.
- troupo 2y agoThere has never been a case where it was escalated so far.
- Teocali 2y agoThis. Each country have an administrative entity (in France, that’s CNIL, Commission National sur l’Informatique et les Libertés - National Commission on computer and liberties, roughly) in charge of this kind oh things. You can lodge a complaint to them and they will investigate and eventually, if needed (don’t think it was ever needed, they can bring the problem to a judge.
- stickfigure 2y agoI have a very difficult time imaging that companies in China (or even the US) will even read a message in French, much less respond to it.
- miki123211 2y agoBut that only applies to companies that the EU has any kind of control over. If you're in a hypothetical country that the EU has no relevant treaties with, the EU has no power over you. They might claim that EU laws are extraterritorial and affect everybody who dares to appear on the internet without blocking EU citizens, but that claim can't be enforced in such a country.
- deleted 2y ago[deleted]
- octopoc 2y agoAt what scale do I need to worry about this? If I make an app and don’t want to comply but I live in the US, do I open myself up to extradition if I have users in the EU?
- sammy2255 2y agoYou don’t worry. The best the EU can do is try (and likely fail) to block access to your application
- sroussey 2y agoFor an app, get you kicked off the App Store.
- Teocali 2y agoThey will block you through DNS. For 99% of the users base, it’s generally enough.
- miki123211 2y agoThe EU doesn't even have a continent-wide DNS-blocking system. Most countries have their own, but they're mostly for copyright infringement, not GDPR violations. Even that isn't universal, Poland's system only affects unregistered gambling websites for example, and I've seen quite a few ISPs that don't even bother enforcing it, even though they're legally supposed to do so. There's nothing (except talking to your government) that the EU could realistically do at this time to block a website, and I genuinely don't know how receptive the US would be to these arguments. The largest "hook" the EU has is that most companies that provide services to you, whether that'd be payment processors, hosting services or ad networks, (still) want to maintain good relations with them and don't want to burn bridges, and I don't believe it's beneath the European commission to put pressure on those to make your life difficult.
- wredue 2y agoAnd that’s the way it *should* be. When Steven Harper unilaterally attempted to empower private data to be offshored, it would have been an absolute nightmare. North American security is bad enough as it is. Imagine handing all your health, credit card, government information over to a Nigerian prince just for free.
- gcbirzan 2y agoI'm not sure about Chinese law, or any other law, but GDPR for sure does not require that. The fact that the US is not an option doesn't mean you cannot store data in any other country, just that the safe harbour and then the privacy shield were considered inadequate. For example, storing personal data in the UK is just fine.
- M2Ys4U 2y agoThe EU does not require data to be hosted locally, though.
- Teocali 2y agoAs far as I know, they do. That’s part of their consumer data protection act (didn’t remember the exact name). Do you have any source for that ? it would n’a quite helpful, honestly.
- com 2y agoThe EU GDPR has requirements for processing (including storage) of personal data (much larger scope than US PII, but still nowhere near all data) in jurisdictions with legal adequacy for data protection. It’s not quite data sovereignty like India’s regulations around payment transaction data but it does theoretically limit where you can store EU personal data. You can find the current GDPR adequacy list at the EU’s EDPB site. https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en https://commission.europa.eu/law/law-topic/data-protection/i...
- cccbbbaaa 2y agoThe law you're thinking about is GDPR. It does allow to host data outside of the EU if the rights of the data subjects are not weakened. Source: GDPR articles 44, 45, and 46.