Re: GDPR - we think we're ready, let me know of any issues


Georg Link
 

Thanks David,

It might be helpful to additionally document how long activity logs are kept and when they are either anonymized or deleted. Because the goal "to detect and fix erroneous behavior, as well to detect and counter malicious behavior" might not require the data for eternity.

Best,
Georg


On Mon, May 14, 2018, 15:14 Wheeler, David A <dwheeler@...> wrote:

The system does store activity logs for all requests to the website.  These logs are necessary to detect and fix erroneous behavior, as well to detect and counter malicious behavior.  For logging to meet these requirements, it is necessary and important to record a variety of information, including the specific request, a summary of what action was performed on the request, the IP address of the requester, and also the user id of a logged-in user where relevant.  Therefore, our logs (like most logs) record this data (IP addresses and user id numbers).  We believe that being able to fix erroneous behaviors of the website, and counter malicious behaviors directed against this website, is a legitimate interest.  We do not use the logs for profiling users for marketing or anything like that; we use the logs to help ensure that the site continues to work in spite of errors or network attack.  We do not provide log data to external users, as that could breach others' privacy.  We b
 elieve this is fine under the GDPR; the GDPR requires "data portability" where consent is granted or the data is provided in performance of a contract, but log data is recorded to support a legitimate interest (and thus is not subject to data portability requirements).

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