4 ms·

By design, I suspect, so they can prosecute those who they don't like (but not their "friends")

by nomdep 2y ago

barbazoo 2y ago
Can you elaborate? Have they in the past used this to "prosecute those who they don't like"?
- wrineha2 2y ago
  EU/EC officials aren't secret that they make as much as possible illegal to get companies to come in and talk with them before they launch products. I have heard this at least twice from the source and more than a couple times from other people I know.
lxgr 2y ago
Do you have any evidence to offer for that claim, other than a personal suspicion?
- nomdep 2y ago
  Of course not, it's just a feeling, and it's probably not the intention of some of the people writing those rules
abeppu 2y ago
I'm not saying this doesn't happen, but I also think it's genuinely difficult to write policies that apply to technical systems that don't exist at the time of writing and which are also clear enough that regulators, courts, and the relevant parties within tech companies all understand what they mean, what they imply about technical systems, etc. With respect to much older law, e.g. copyright, I think we still haven't fully interpreted what constitutes "copying" or "distributing" in a digital context. With respect to data privacy, though I was part of a team that was responsible for ensuring my company met GDPR obligations, it's still not clear to me what really constitutes deletion or erasure for these purposes. What if my DB doesn't delete stuff on disk immediately but marks some records with an in-memory tombstone, so normal DB queries will no longer return the record but files containing the record do still exist? Am I obliged to delete all DB backups when any individual exercises their deletion rights? If my datalake uses columnar files that record events (e.g. clickstream data) from many users, every time any user exercises their deletion rights, do I have to re-write all the files that included any event from them? To find all files containing a user efficiently, I'd probably need to start indexing by user, which if anything puts my team on the path to using user-specific data more intensively going forward. Or is it sufficient to mark their ID in a "forgotten" file and ensure that datalake results do not include information from their records, though the records are in principle still readable? If you didn't have a good systems/data engineer participating in the drafting of the policy, it's easy for a regulator to just write "delete" without thinking through what the actual definition should be, and what the implications are.
- amiga386 2y ago
  > Am I obliged to delete all DB backups when any individual exercises their deletion rights? No, just don't use that individual's data in any processing going forward, unless you have a lawful basis for doing so. If you restore from those backups, don't lose the fact this individual exercised their right to be forgotton. > What if my DB doesn't delete stuff on disk immediately but marks some records with an in-memory tombstone, so normal DB queries will no longer return the record but files containing the record do still exist? If you don't process those records any more, that's fine. Ideally purge your database tables from time to time, because you should also have retention limits, set to the minimum possible. "Forever" is not an acceptable limit for PII. > do I have to re-write all the files that included any event from them? No. Write a list of users whose events you mustn't process any more, and preferably stop collecting events for those users... assuming that specific data you're collecting is data which you don't have a legal basis to process without their continuing consent. If they withdraw consent, you have to stop. It's that simple. Design with that in mind. > the records are in principle still readable? It doesn't matter about "in principle", it matters if you continue to process the data of individuals who have exercised their right to be forgotton and withdrawn their consent, and you have no other lawful basis with which to continue processing their data. > which if anything puts my team on the path to using user-specific data more intensively going forward "The 'no beatings' law just makes we want to beat people even harder". You sound petty. Treat PII as if it were hazardous waste; minimise your collection of it and processing of it, dispose of it as soon as you can. > it's easy for a regulator to just write "delete" without thinking through what the actual definition should be, and what the implications are. They did think it through. Section 67 of the GDPR: "Methods by which to restrict the processing of personal data could include, inter alia, temporarily moving the selected data to another processing system, making the selected personal data unavailable to users, or temporarily removing published data from a website. In automated filing systems, the restriction of processing should in principle be ensured by technical means in such a manner that the personal data are not subject to further processing operations and cannot be changed. The fact that the processing of personal data is restricted should be clearly indicated in the system." Read the rest of the statute, it's not that difficult to understand: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL... You just don't like having to do it, and would prefer if once a user gives consent (or even if they don't), you can keep that data and do anything you like with it for all time and there's nothing the user can do about it.

By design, I suspect, so they can prosecute those who they don't like (but not their "friends")

by nomdep 2y ago

By design, I suspect, so they can prosecute those who they don't like (but not their "friends")

barbazoo 2y ago

Can you elaborate? Have they in the past used this to "prosecute those who they don't like"?

wrineha2 2y ago
EU/EC officials aren't secret that they make as much as possible illegal to get companies to come in and talk with them before they launch products. I have heard this at least twice from the source and more than a couple times from other people I know.

lxgr 2y ago

Do you have any evidence to offer for that claim, other than a personal suspicion?

nomdep 2y ago
Of course not, it's just a feeling, and it's probably not the intention of some of the people writing those rules

abeppu 2y ago

I'm not saying this doesn't happen, but I also think it's genuinely difficult to write policies that apply to technical systems that don't exist at the time of writing and which are also clear enough that regulators, courts, and the relevant parties within tech companies all understand what they mean, what they imply about technical systems, etc. With respect to much older law, e.g. copyright, I think we still haven't fully interpreted what constitutes "copying" or "distributing" in a digital context. With respect to data privacy, though I was part of a team that was responsible for ensuring my company met GDPR obligations, it's still not clear to me what really constitutes deletion or erasure for these purposes. What if my DB doesn't delete stuff on disk immediately but marks some records with an in-memory tombstone, so normal DB queries will no longer return the record but files containing the record do still exist? Am I obliged to delete all DB backups when any individual exercises their deletion rights? If my datalake uses columnar files that record events (e.g. clickstream data) from many users, every time any user exercises their deletion rights, do I have to re-write all the files that included any event from them? To find all files containing a user efficiently, I'd probably need to start indexing by user, which if anything puts my team on the path to using user-specific data more intensively going forward. Or is it sufficient to mark their ID in a "forgotten" file and ensure that datalake results do not include information from their records, though the records are in principle still readable? If you didn't have a good systems/data engineer participating in the drafting of the policy, it's easy for a regulator to just write "delete" without thinking through what the actual definition should be, and what the implications are.

amiga386 2y ago
> Am I obliged to delete all DB backups when any individual exercises their deletion rights? No, just don't use that individual's data in any processing going forward, unless you have a lawful basis for doing so. If you restore from those backups, don't lose the fact this individual exercised their right to be forgotton. > What if my DB doesn't delete stuff on disk immediately but marks some records with an in-memory tombstone, so normal DB queries will no longer return the record but files containing the record do still exist? If you don't process those records any more, that's fine. Ideally purge your database tables from time to time, because you should also have retention limits, set to the minimum possible. "Forever" is not an acceptable limit for PII. > do I have to re-write all the files that included any event from them? No. Write a list of users whose events you mustn't process any more, and preferably stop collecting events for those users... assuming that specific data you're collecting is data which you don't have a legal basis to process without their continuing consent. If they withdraw consent, you have to stop. It's that simple. Design with that in mind. > the records are in principle still readable? It doesn't matter about "in principle", it matters if you continue to process the data of individuals who have exercised their right to be forgotton and withdrawn their consent, and you have no other lawful basis with which to continue processing their data. > which if anything puts my team on the path to using user-specific data more intensively going forward "The 'no beatings' law just makes we want to beat people even harder". You sound petty. Treat PII as if it were hazardous waste; minimise your collection of it and processing of it, dispose of it as soon as you can. > it's easy for a regulator to just write "delete" without thinking through what the actual definition should be, and what the implications are. They did think it through. Section 67 of the GDPR: "Methods by which to restrict the processing of personal data could include, inter alia, temporarily moving the selected data to another processing system, making the selected personal data unavailable to users, or temporarily removing published data from a website. In automated filing systems, the restriction of processing should in principle be ensured by technical means in such a manner that the personal data are not subject to further processing operations and cannot be changed. The fact that the processing of personal data is restricted should be clearly indicated in the system." Read the rest of the statute, it's not that difficult to understand: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL... You just don't like having to do it, and would prefer if once a user gives consent (or even if they don't), you can keep that data and do anything you like with it for all time and there's nothing the user can do about it.