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GDPR compliance notice

Some of you might be aware of the GDPR (General Data Protection Regulation) that comes into force throughout the EU on May 25th. (For a broader lay person's introduction, see this essay by Jacques Mattheij.)

Here's what you need to know about this website and GDPR:

  • This may look like a personal blog, and as such you might think it's exempt from GDPR (Article 2 states that the regulation doesn't apply to processing of personal data "by a natural person in the course of a purely personal or household activity"). However, this blog is an adjunct to my business (writing novels) and is used for marketing purposes from time to time (carrying marketing information about my books, and links to third parties selling them). Prudence dictates that I should comply with the requirements of the GDPR—not to mention ethics: GDPR is about protecting individuals' privacy, and I'm all in favour of that.

  • I do business on such a small scale that, essentially, I'm responsible for everything on this website. (I sometimes pay other folks consultancy fees to do design or technical maintenance tasks I'm not competent to do myself.) Thus, all the corporate roles and responsibilities outlined in GDPR (such as the Data Protection Officer) devolve to me.

  • This website retains blog entries and blog comments. By posting an entry on this blog, or by commenting on an entry, you are implicitly agreeing to let me republish your material around the world. (This is mentioned in the moderation policy which you were advised to read before commenting, and I make it clear to the invited guest bloggers in their intro email.)

  • EDIT Spamming is a violation of the moderation policy of this blog and strictly forbidden. The blog uses external third-party services (specifically Akismet) to identify and reject spam comments that have been posted to multiple blogs. Because this is not a Typepad system, I have no access to Akismet-collected metadata about your comments. The content of your comments is publicly accessible, and is made visible to Akismet's service at the time of posting, as a precondition for posting on my blog. If for some reason you don't want your comment to be shared with Akismet, (a) stop commenting, and (b) contact me to have your earlier comments removed.

  • This website runs on top of a software stack using the Apache web server. Yes, Apache saves logfiles. These are only digested for statistical analysis of overall traffic. It also uses cookies to maintain your login session if you create a username and password so that you can comment (or post blog entries). Stuff it knows about you includes the IP address your browser request came from, the page requested, the referrer page (if any), and your browser identification string (if any). If this worries you, you're welcome to use a VPN and obfuscate or anonymize any or all of these things: you won't be blocked (although it may make posting comments problematic if you block cookies and/or javascript).

  • This website does not attempt to track you, does not knowingly feed your personally identifiable information to any other business or advertising affiliate or network—I don't even use Google Analytics—and I don't intend to start collecting or processing personal identifiable information.

  • This website may leak information about your session to third parties if you allow it to load content in the sidebar from Zazzle.co.uk (hint: the merchandise links), and if you view it with image loading enabled (I sometimes post image links that direct to websites I don't control).

  • Many years ago I ran a mailing list; this is now discontinued/deleted. More recently I set up a Google Group (antipope-storm-shelter or some such), so long ago I've lost track of it. That is covered by Google's GDPR compliance policy. If I ever decide to relaunch my author mailing list, I will do so by outsourcing operations to a third party organization that is GDPR compliant, and I will only ever operate a mailing list on a strict opt-in basis: I will never harvest your email address from your blog login for my own, or a third party's, mailing list.

  • If you want to exercise your right to be forgotten, or have personal information removed from this site, Contact me via this link if you don't already have my email address, or DM me on Twitter (@cstross). I do not use Facebook: requests made via Facebook will probably be missed. Note that I am not a corporation with a dedicated IT support staff and I spend 4-10 weeks of each year traveling, frequently without a laptop. If you don't get a reply within a week, email me again—I probably didn't get your request or I was swamped by other stuff.

  • Once I receive a GDPR request I will comply with it promptly, but bear in mind I'm a human being with a day job, and this blog is a peripheral pursuit. If your requests become an irritant (e.g. if you request multiple fiddly comment deletions or edits across multiple threads) I may just erase all your content and ban you from the blog in future. (GDPR gives you a right to be forgotten; it does not impose an obligation to be remembered.)

Any questions? Ask below. Use this link for GDPR requests

77 Comments

| Leave a comment
1:

Thanks, Charlie. Even though GDPR compliance is a big part of my day job right now, I was not aware of the Article 2 exemption for personal use. I don’t have to worry about expunging or obfuscating IPs from my blog’s web server logsany more.

2:

Just a reminder that *purely* an IP address, without additional details (like any of name, email, postal address etc.) is not personal data. It's only if you have other data that together with the IP address would identify someone that it is - CJEU 582/14 Patrick Breyer v Germany.

3:

Just a reminder that *purely* an IP address, without additional details is not personal data. It's only if you have other data that together with the IP address would identify someone that it is

That case applies to dynamic IP addresses. I have fixed IP addresses and any technically competent person can find my name, address and telephone number from my IP address alone(*) so it does count as personal data.

(*) Until ICANN gets its act together and does something about GDPR.

4:

Sigh. I appreciate that you look out for your readers, but in a sane world, you could have saved half your words by saying "This is a normal website. It receives any data you or your browser send to it."

5:

With the best will in the world, windypundit, talking about being compliant with the law isn't about normal people, it's about being seen to be compliant with what the lawyers need. Anyone who thinks lawyers are normal people needs a reality check...

6:

Unfortunately there hasn't been any such thing as a "normal" website since probably 1996-97.

More realistically: the web, as we received it, was built out on the back of advertising and retail revenue. Consequently, we got into an advertising arms race. This in turn provided perverse incentives to collect more and more personal data by any invasive mechanism available, and the existence of large jurisdictions with only very weak constitutional privacy laws (specifically the United States) allowed some really terrible practices to become industry norms.

GDPR is a well-intentioned attempt to, if not put the genie back in the bottle, then at least to serve notice on companies like Cambridge Analytica (and Facebook) that their abuses of personal privacy are in fact illegal and may be prosecuted unless they follow these guidelines.

If you don't voraciously collect personal identifiable information or process people's intimate details abusively -- by which, I mean material which would have been considered intimate if not confidential or secret prior to the world wide web, but which is now the stock-in-trade of advertising networks -- then GDPR should be utterly unproblematic.

(Note that a lot of FUD is currently being spread by consulting companies who want to panic mid-to-large corporations into paying them big bucks for training, certification, and compliance services. Much as the antivirus industry promotes fear of malware but doesn't make it any easier to secure your computing environment ... unless you pay for their products. Caveat emptor!)

7:

I know what you mean, but to me it's incredibly tedious to read through privacy-related notices that recite in great detail that they are collecting (a) data I give them and (b) data that practically every web browser has sent to web servers since HTTP was invented.

Then they tell me that they will use that data in their normal and easily-predicted business processes in the course of dealing with me as a customer.

It's all not really necessary, and it feels like (and in some cases, I'm sure it is) an attempt to obscure what I really want to know: Are they going to share my data with people who will do things that upset me?

8:

Well done sir, for producing probably the best-written and least tedious GDPR disclaimer I have yet seen, and I have had to complete the standard GDPR and Personal Information Handling course where I work.

I prefer yours; easier to understand and legal with it; nice.

9:

My own personal webiste resembles that remark!

On the other hand, here's a question, Charlie: assuming I ever sit the hell down and get my coding done, I'm intending to stand up a website that cons can link to (I'm starting in the US, I do *not* want to deal with unicode) that is intended to be a place for folks to buy/sell con memberships, and to find/offer roomsharing at cons. I'll want folks to register with a name and email. Beyond that, I wouldn't be storing anything. There is NO FUCKING WAY that I would even consider selling or sharing that d/b.

Is there something in there that would be in violation of the GDPR that you can see?

10:

Regarding: "jurisdictions with only very weak constitutional privacy laws".

You believe that a person's privacy should be constitutionally protected from other than government intrusion? Here in the United States, we could make corporate intrusions of our privacy illegal, if we wanted to. We should probably put some thought into why we haven't (or where we have, why we don't enforce the laws we do have).

If this is derailing your comment section feel free to moderate it out.

11:

IANAL!

Something to remember: the GDPR is essentially sane. The salient points are "don't collect personal data you don't really need, when you do things with personal data do it with explicit permission, allow people to tell you to remove their personal data". And that's modulated by common sense: for instance in your case the name (which may not be the legal name) and the email (which is necessary to communicate) are needed to provide the service the person wants, so you implicitely have authorization. And you don't have to remove data you have to keep for legal reasons like accounting, reimbursements, etc.

The rest is mostly about having an identifiable, authoritative contact point for people to ask about the personal information of theirs you have and have it removed if they want to. Charlie has shown beautifully that does not require any heavy mechanisms.

12:

It also uses cookies to maintain your login session if you create a username and password so that you can comment ....
And it &/or my computer are screwing with that process at the moment - I THINK I've changed my password, but I have to re-enter it every time, since it seems to be "remebering" the old one ....

Otherwise, sounds / looks entirely good to me & - echoing Dan M @ 8
THANK YOU Charlie excellent stuff.

P.S It's called: "Antipope Strom Refuge" - set up (IIRC) when you had a SPAM overload ?

13:

You believe that a person's privacy should be constitutionally protected from other than government intrusion? Here in the United States

Yes. I am not in the United States.

GDPR was drafted because the EU (and Europe in general) runs in accordance with the ECHR, the European Convention on Human Rights, which is a bill of rights that was drafted after the atrocities and massacres of the second world war (unlike the bill of rights in the US Constitution).

The ECHR provides for a right to privacy, because back before 1939, most Europeans didn't have such a right, and millions of them died as a result -- the excess of data floating around made it too damned easy for the Nazis to round up and murder their victims when they rolled through. I'd say that preventing people becoming victims of genocide is a fairly critical justification for enumerating a specific human right, wouldn't you agree?

The US Constitution was a pretty good first draft ... for a slaveowning collection of colonies in the 1780s. Times have moved on, and these days it's deficient and unable to keep up. Sometimes the difficulty of passing amendments is a good thing, and sometimes it's actively harmful. In my opinion, the biggest problem with the US Constitution isn't what's in it -- it's the interpretation: specifically, the fatal blunder of allowing case law to build up that enshrines the pernicious and dangerous doctrine that companies are legal persons with the same rights as actual persons, but without responsibilities (to the actual persons around them) that reflect their great power.

14:

Antipope STORM Refuge, dammit (!)

15:

and there I was all curious about what a shelter for electricity looked like
(SCNR)

16:

Thanks for answering. I'm sorry I asked a slightly rhetorical question when what I really wanted to know was why you think privacy should be constitutionally protected.

I understand the problem with recognizing corporations as having the rights of persons: I'm exceedingly frustrated that this has been given with no concomitant requirement for responsibility. I of a mind that the rights should be rescinded and the responsibilities still be required.

The argument that's been given to me is that as long as liberty is guaranteed, we can get as much privacy as we are able to legislate. I don't believe that, but I think it is the general idea behind a constitution that solely defines the role of the government, as opposed to citizens or (and this is where it goes wrong) government sanctioned artificial legal entities. I don't care for the fact that our government can pay the phone company to store all of our phone records until they need them. And then they get a warrant to look at them.

And finally, yes, preventing genocide is a perfectly good reason to enumerate a specific human right. I hope it works.

Thanks again for taking the time to answer my question.

17:

As ever, girls with cooties never get invited to the treehouse.

~

@Host - if anyone requests any of our multiplicity deleted (rather than via Legal Note), just disregard.

No-take-backs etc.

18:

Name and email are both personal data under GDPR. If you are never going to deal with anyone in the EU, you can completely ignore it. If you are going to be passing personal data to or from anyone in the EU, they you are going to want to take account of it. From what you are saying, you are already half way to an acceptable GDPR statement, so you shouldn't have any trouble drawing one up.

If you want all the rules from the horses mouth, you can go to the EU Commission site at https://ec.europa.eu/info/law/law-topic/data-protection_en

If you are having problems sleeping, the whole GDPR in English is at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN

19:

Read the GDPR a while back out of curiosity. The aspect that struck me the most (am from the land of lawyers, USA, am not one) is that much of the language has deliberate wriggle room. The case law will get built out but it seems likely a lot of corporations (probably many non-European) will get badly burned in the process.

The right to be forgotten is particularly bold. It will be interesting to see how it intersects with things like blockchains [1] and grey areas like surveillance videos (of public and commercial venues), before and after AI methods are used to add person-identification metadata.
(If anyone knows of any decent analyses of these two in particular please post a link.)

[1] some blockchains are about not forgetting among other things, e.g. http://arno.uvt.nl/show.cgi?fid=143638 pg 34

20:

"I'm starting in the US, I do *not* want to deal with unicode"

At risk of derailing this thread so soon, but it is about websites...

Why? What's so hard about unicode? Don't most programming languages cope with it just fine?

I'd have thought that as a matter of respect for people who use your site you'd use a character encoding that lets them spell their name correctly. Whether that name is Zoltán Brust, Björk Guðmundsdóttir or Stanisław Lem.

(Yeah, I know, Lem's dead so he's not likely to come to your con. At least I hope not.)

Which does not necessarily imply unicode, but does mean thinking seriously about character encoding from the start.

21:

The other thing I'm wondering on this whole mess is how it's going to interact with machine learning and other mass-data efforts.

Lets say you're an EU citizen who has a gMail account dating back to the old days when it was invite only. Google does something you don't like, or you run afoul of their automated policy violation detector, and you delete your account and submit a formal request for all your data to be forgotten.
Google's fancy spam filter has years of your email baked into it's big detection matrix. There's no way to unwind that without GPU-centuries of computation. Sure you probably can't extract the PII from that but it's still there. According to GDPR that's no excuse and Google should have to delete and start over.

22:

Thanks Charlie -

I am a big fan of GDPR, and you may well have supplied a model GDPR declaration.

There are *intended* consequences to the new laws, and one of them is that website owners are being forced to confront what their sites, their adverisers, and their data collection practices actually do; and they are being forced to tell their users about it.

23:

Google's fancy spam filter has years of your email baked into it's big detection matrix.
Or, +20 years, that spam filter is now a thoroughly integrated part of a corporate AI entity that some argue is sentient. Do we "natural persons" have the right to demand that it acts on a continuous stream of requests to forget individual natural persons? Creating large numbers of holes in its memories, that it can sense.

24:

...machine learning and other mass-data efforts... Google's fancy spam filter has years of your email baked into it's big detection matrix

I'm not sure there's a real problem there.

If you're talking about your footprint in a convoluted neural network then they can't unwind it, but I'd deny that it was really personal information any more.

I think a fair analogy is to the way that you and other people taking a short-cut has created a dirt track across the lawn - yes, your footprints helped make that path, but it's not really showing *your* footprints in any real sense.

Although Strava's Global Hotspots might take on just that analogy and show that I'm wrong. They're the most commonly used app to track running and cycling, and in November they started releasing an anonymized map constructed by them from a couple of trillion or so geolocation points showing global hotspots showing where lots of people run/bike using their app, which accidentally revealed where large groups of US military personnel are in Africa and the Middle East. They still release it and keep it up to date monthly.

25:

wow! clear, concise, useful? You sure this article is about GDPR? :)

(I support GDPR, I just think it's deliberately too ambiguous in many areas, which is going to keep lawyers happy for decades)

26:

Somewhat off topic but tangentially related, Google has finally stopped paying lip service to not being evil.

27:

I haven't been closely involved in this area for a decade now, but UK law had some 'interesting' exemptions, and they were used. In particular, data had a tendence to leak across the Atlantic, including commercially sensitive and sensitive personal data, with Whitehall approval and damn-all chance of a redress in the courts. While that doesn't affect OGH's post or Web site, it almost certainly does affect all connections to it (because of the laws relating to ISP's data).

28:

@Host - if anyone requests any of our multiplicity deleted (rather than via Legal Note), just disregard.

Noted. (I can see why that might be an issue.)

29:

Whitroth, before writing any kind of data handling app that organizes peoples' names, you should be sure to read falsehoods programmers believe about names.

Once your head stops hurting, Unicode will seem trivial.

30:

GDPR needs to be ambiguous; too much specificity is what brought us the not-fit-for-purpose EU cookie directive.

That is: the intention behind the cookie directive was good, but cookies were a specific technology, they could be used in various ways, and they weren't the only way of fingerprinting or tracking users across the web -- the bad actors just switched to different tracking technologies while the law-abiding websites vomited stupid pop-up warnings everywhere.

By not tying GDPR to a specific technology, and by allowing some wiggle room, the judges can adjudicate and create case law to deal with currently-unanticipated abuses.

31:

EU directives and laws -- e.g. the ECHR -- tend to include blanket loop-holes for national security, public health, and public safety. They often (although less often in recent years) contain get-outs for "defense of public morals".

(The USA is no better, although the loopholes tended to be unwritten in the constitution and applied ad hoc at state level; e.g. all sex outside heterosexual marriage was a felony in many states until the 1960s, as was contraception, and that's before we consider the Comstock Laws and how they played fast and loose with the First Amendment.)

32:

I wonder if the ECHR and GDPR are going to be an issue for Britain after Brexit.

33:

I wonder if the ECHR and GDPR are going to be an issue for Britain after Brexit.

The ECHR has nothing to do with the EU so is unaffected by Brexit, (although certain Tories and right wing tabloids hate it). GDPR is a consideration for anyone who keeps personal details of EU citizens no matter where on the planet the data gatherer exists. So the only thing affected by Brexit is handling personal details of UK citizens, and we'll have to see what the government does about that.

34:

I was peripherally involved with the developing ISO standard that was largely kicked into the long grass by Unicode, and it's worse than even that.

35:

Er, no. While that is the case in theory, one of May's red lines is to break away from the ECHR. It's also tied up with several aspects of even the most basic Brexit.

36:

Whitroth, before writing any kind of data handling app that organizes peoples' names, you should be sure to read falsehoods programmers believe about names.

Not just programmers:

https://www.nytimes.com/2018/05/09/world/asia/mike-pompeo-kim-jong-un-name.html
[Secretary of State Mike Pompeo] committed a faux pas by saying that the United States was beginning “to put some outlines around the substance of the agenda for the summit between the president and Chairman Un.”

And I once had to attempt to explain to a programmer that Russian names spelled in Cyrillic could transliterate into "English" in several different ways. I'm pretty sure I failed at that one.

Of course, the Spanish $First_Given_Name(s)_$Other_Names(s)_$Patronymic_$Matronymic creates endless confusion here in the US. Especially because the "Last Name" is the patronymic second-to-last, not the matronymic last. E.g., a recent President of Mexico was Felipe de Jesús Calderón Hinojosa, properly called Presidente Calderón.


37:

A related google story that's been making the rounds is Google’s Selfish Ledger is an unsettling vision of Silicon Valley social engineering. The GDPR monkey-wrenches some of that a bit.
(Worth a read IMO.)
Building on the ledger idea, the middle section of the video presents a conceptual Resolutions by Google system, in which Google prompts users to select a life goal and then guides them toward it in every interaction they have with their phone. The examples, which would “reflect Google’s values as an organization,” include urging you to try a more environmentally friendly option when hailing an Uber or directing you to buy locally grown produce from Safeway.


38:

That article should have a shout-out for the Dutch. Consider Nobel laureate Gerard 't Hooft. That’s right, his family name starts with an apostrophe. Which is why in his town phone book he’s listed under “H”.

39:

Actuaries of my acquaintance are worrying about exactly this problem with their tables...

40:

I think I've seen L. Sprague de Camp's books filed variously under C, D, and S.

41:

And I once had to attempt to explain to a programmer that Russian names spelled in Cyrillic could transliterate into "English" in several different ways. I'm pretty sure I failed at that one.

Somewhat related my wife works on the corp side of a major airline. They were getting ready to roll out a new (or updated) application that would generate text messages to customers in some situations. And if the customer record had a language tag it could generate the message in one of about 8 languages.

Some wing nut in the testing group decided to run the resulting non-English (US) output through the Google translate site and filed bug reports saying the messages didn't come back to the correct English.

[Head thumping on desk.]
What a way to waste several man hours all around as my wife had to work up a response to this as the bug reports were "official".

42:

"all the corporate roles and responsibilities outlined in GDPR (such as the Data Protection Officer) devolve to me"

Please don't call yourself DPO if you don't require one! Just giving yourself that title creates legal responsibilities you almost certainly do not need.

43:

"I think I've seen L. Sprague de Camp's books filed variously under C, D, and S."

What letter of the alphabet would they be properly shelved under?

44:

I have read some rules about how names should be alphabetized, though only in Finnish. Apparently it depends on what the language is - 'de' is sometimes taken into account, and sometimes not. I don't know what language should be used here. For example in Spanish the 'de' is not part of the surname, so it would be under 'C', but in Italian it would be part of it, so under 'D'.

There is a Finnish standard (SFS 4600) which determines this, and it has that language dependency. It apparently says nothing about American names, so I'd probably decide something and then try to communicate it to the possible users.

(I think the surname here is 'de Camp'.)

45:

What letter of the alphabet would they be properly shelved under?

There's undoubtedly a bunch of contradictory standards for this.

https://www.dartmouth.edu/~library/recmgmt/forms/FilingRules.pdf

Rule 2:
Surnames which include prefixes such as D', Da, De, Del, De la, Della, Den, Des, Di, Du, El, Fitz, L', La, Las, Le, Les, Lo, Los, M', Mac, Mc, O', Saint, St., Ste., Te, Ten, Ter, Van, Van der, Von, etc.. are filed as one word in alphabetical order.
D' Genoa -> Dgenoa
de Silva -> Desilva
Van Der Liden -> VanderLiden

Etc.

46:

It's a long time since I last looked in the phone book -- cellphones aren't listed and many people have gone ex-directory to avoid phone spammers, so it's a shadow of its former self -- but about a third of the Edinburgh telephone directory consists of names beginning with the letter 'M', and most of them are under "Mac" -- and relatively few "Mac's" at that: MacDonald runs to many pages.

47:

There is a Finnish standard (SFS 4600) which determines this, and it has that language dependency. It apparently says nothing about American names

Welcome to the USA. In reality there are no "American" names. They are all from elsewhere. English, Welsh, French, Italian, whatever. So strictly speaking, alphabetization here might require you to guess the national origins of the name.

48:

...about a third of the Edinburgh telephone directory consists of names beginning with the letter 'M', and most of them are under "Mac" ...

A colleague who used to work for BT insisted that their directory programs assumed an extra letter of the alphabet - covering both Mc and Mac (viewed as equivalent for sorting purposes).

So, alphabetical order in a UK phone book would be McArthur, MacDonald, Mabel.

49:

Charlie wrote: Once your head stops hurting, Unicode will seem trivial.

I will add that assuming you're not planning to write your website backend code in C, Unicode is trivial. (At least for what you've described.) All the major web frameworks I'm familiar with, whether Java, Python, Ruby, or Node, are built around Unicode strings from the ground up. It would be more work to be ASCII only.

Don't let the horror stories about name sorting put you off. The problems exist and are very real, but I doubt you will be affected. Sorting in a library or phone book matters because people want to find names efficiently. For what you've described, people will want to find cons or rooms, not other people. I would use whatever sort order your web framework gives (and again they're pretty good about adapting to different locales these days) and not worry about it.

50:

I will add that assuming you're not planning to write your website backend code in C, Unicode is trivial.

That was kind of my point. It's a default for most web frameworks (unless you look really closely at the relationship between UTF-8 and unicode, but lets not), so why avoid it or fear it?

It does have its problems. But if someone wants their name to be written entirely in emoji then 🙈🙀🙊

51:

I've seen L. Sprague de Camp's books filed variously under C, D, and S.

I used to confuse people by filing my music alphabetically using the artist's name, originally excluding one leading "the" but eventually not (it's complicated as quite a lot of bands add and drop the leading 'the' seemingly at random. Fortunately Matt Johnson doesn't do that).

It's confused because people often try to use the artists surname and the bands full name, so "Bob Marley and the Wailers" goes under B, but Bob Marley goes under M. Even they can be confused by asking whether Pink Floyd the band goes under P for the band name or F for the character name (the band refer to a singular "Pink isn't well, he stayed back at the hotel" for example).

But yeah, naming is fun. Especially "throw away all but first and last names" systems when given Spanish (given matronymic), Vietnamese (Ms patronymic), Philippines (formal-name area-of-origin) and so on. Plus cultures where the first name in a family is often traditional (I have two uncles William, and 9 great-uncles William - only one known by that name or a variant, but three of them are 'William Smith' and all of those have the same parents)

52:

Yeah, that's kind of the problem. Generally there is no way of knowing how the different parts should be handled, so in my opinion (as an occasional developer by trade) there should be one set of documented rules for all names, at least inside a certain system. In many cases I wouldn't know if the name was Spanish or Italian anyway.

However, asking things like "how should the edge cases for names be handled?" from somebody responsible for the requirements of an application has rarely produced any good results. I remember one time we needed a decision on how to save timestamps in some file metadata (not filesystem times, but other times, for various reasons) for things which could go over time zones repeatedly, and it took two weeks to get the approval for the only technically valid decision (save the timestamp in the metadata in UTC, and display it correctly for the current timezone).

53:

That is the traditional, correct collation order. It's quite common for different members of a family to use different variants of 'Mac'. But it also means that Maclean should come before Machin :-)

54:

UTC is OK, if seconds aren't critical, but not if they are. Those of us with nous never did persuade the POSIX and NTP people that using TAI and offsets was the only sane solution, in cases where they DO matter. POSIX timestamps are completely broken in that case, and NTP isn't great.

On a related matter, I was peripherally involved in the POSIX standardisation of timezones, and one proponent claimed that their scheme covered all possible time zones. I pointed out that it didn't cover solar time and didn't even cover the UK. His claim that there weren't any of the former was wrong, and asked me what the rule was for the UK, claiming he could write an algorithm for it, which was also wrong. So here it is:

There is a rule in the enabling Act, which has never been used. The actual rule is decided by Parliament 6 months in advance (and once, in my memory, in arrears), though recently it has been established for longer and may now be fixed (I haven't checked recently). Also, there was once a proposal for double 'summer time' - no, not merely a 2 hour shift, but 4 changes in a year - the airline, shipping and similar companies then jumped on the PM (Wilson) in a body!

55:

Generally there is no way of knowing how the different parts should be handled, so in my opinion (as an occasional developer by trade) there should be one set of documented rules for all names, at least inside a certain system.

The best system I've seen had one (largish) text field for "your name" and another one for "what short name do you like to be called by?". That immediately avoids any assumption about name structure and allows personal preferences. For example, a Japanese friend of mine likes to be called "Mack" for short rather than the more usual Furukawa-san, which no algorithm is going to get right.

56:

Yes, but Hobbes got to be invited to tea by Susie. Calvin and his dad were idiots.

If I ever win the lottery (I know, I know, buy a ticket), and can afford to come to the UK again, I'd invite you to tea....

57:

Yeah, well, a) I have a really good idea of names - I've had a long career, starting with three years at a community college, and a few years later, I spent a year and a half at the Scummy Mortgage Co.

As a side note, my twins, including the divorced one, both took their husband's name, because they were really *really* tired of Amurkans being unable to deal with a hyphenated last name.

Note that I'm actually not worried about names, other than an login name. I'm planning on only enabling this, not being involved. Still, I figured on slowly offering it to cons in the US, since IANAIL, and don't want to deal with international laws. Once it's done, and the code will be available, someone else can expand.

I've semi-promised a friend (also a programmer) that eventually, once v 1.0 was out, I'd consider v 1.5, or maybe it's v. 2.0, that also had an icebreaker.

58:

They've also stopped caring about anyone on a real computer. Mid-day Friday, they changed news.google.com to be aggressively hostile to anyone *not* using it on a stupidphone. I *can't*, for example, minimize any story.

59:

Sprague, or as some neofen would address him, Mr. De Camp, would respond to both.

Yes, I did know him and his wife. They were local to where I grew up, and were always at Philcon.

60:

First, I would say with a 90% confidence that they're using the SOUNDEX algorithm.

Second... ok , this is an old US-ism, first half of the 20th, I think, for a guy speaking to another guy they didn't know, to call him Mac, as in, "Hey, Mac!"

61:

Write a website backend in C? Why? Certainly not. I'm just extending what I wrote and put as open source about a dozen years ago.

It's a perl CGI, of course.

#insert "nose_in_air.h"

62:

And I would say with rather greater confidence that they are not! It's specific to the 'Mac' prefix, when meaning clan/son of.

63:

The best system I've seen had one (largish) text field for "your name" and another one for "what short name do you like to be called by?".

Yeah, that works when you can ask people that. For example libraries might need to catalogue books written by dead people, and it can be difficult to ask where in the alphabet their names should be put. Or foreign people - think of how many libraries there are in the world and how feasible it would be for every one of them to ask every author with a "difficult" name, which of course would depend on the local language, too...

64:

FYI Names and travel.

As I've mentioned my wife works for a major airline. And she has said a big issue is when names on passports are not exactly the same as on the boarding pass. They check and deny boarding if traveling between countries. They do this because on arrival at country 2 if the border folks don't like a discrepancy the airline is on the hook to return them on next flight back. If next flight back is full then figure it out. And heaven help the luggage of said passenger.

Any way if your passport says "Blue Box #$# Fred", your boarding pass should say the same.

65:

Hi Charles, a European friend on twitter sent me a link to this post. I have written about my issues with GDPR compliance as a blogger who writes about security, tech and photography but who is also an independent tech consultant living in the USA.

I love what you wrote. It’s way better than the boiler plate I have on my web site.

Is this post creative commons? May I use it as a starting point for my own GDPR compliance notice?

[[ Links fixed - use " style double quotes, the other types don't make valid HTML - mod ]]

66:
Any way if your passport says "Blue Box #$# Fred", your boarding pass should say the same.

Which passport ?

Back to the list of falsehoods OGH posted: I have (at least?) two fully legal names (translations into national languages) and may have passports in both.

67:

Fine. Just use the one that matches your ticket/boarding pass.

Another issue people would run into would be trying to enter a country with one passport and return using a different one. Typically from a different country. Then get upset when the border guards didn't appreciate their desires. And my wife would get a call asking them to fix it with the border folks. Yep. Sure.

My point is the airlines have no desire to be the unpaid transport for people who want to try and talk their way past the border guards. So they will check your papers to make sure the easy stuff doesn't bite them in the butt.

68:

Yes, I'm aware of the "be especially nice to border guards" rule.

I know someone who had their US passport shredded at US Immigration controls when the border guards discovered they were (legally) holding two passports. They can treat actually using dual nationality as a form of treason.

69:

How can the website operator be assured that the person making the deletion request is the ACTUAL person who provided the information the website has stored?

70:

How can the website operator be assured that the person making the deletion request is the ACTUAL person who provided the information the website has stored?

The same way as they can be sure of the identity behind any action on the web site - whatever authorisation mechanism they use. Either request deletions via the web site or get a time limited nonce from the web site to be included in mail requesting deletions. That guarantees the agent requesting deletions has access to the relevant authorisation. Add a three phase handshake and you can deal with many cases of leaked information. Anything else is the user's problem - the GDPR legislation talks about proportionate controls, you don't need sworn copies of birth certificates, finger prints and DNA samples to run a parish newsletter.

71:

So I leave a comment on this website using email address personA@example.com. Some years later, I make an erase request using the form Charlie provide (https://www.antipope.org/charlie/who_am_i/foo.cgi) but under a different email address personB@thisisme.com. How does Charlie honor the request?

72:

I'm not a techie, so it's dumb question/comment time ...

1- I've heard/read that email (and the internet in general) can be bounced around anywhere on the planet umpteen times before landing in your inbox. To me, this means umpteen opportunities for someone to intercept/grab/scan/save whatever PII info is being sent as part of my email. If this is so/accurate, then how will this new legislation serve to protect users? (What's implied but not being stated ...)

2- There's a long history of large orgs relocating when/if they happen to dislike some new piece of legislation in their current geography. So, related to the point/question above, the scummy orgs that rip PII will simply move this portion of their operations to a friendlier land ... and continue selling PII data in the EU same as before because that data was obtained 'legally*' (within a jurisdiction where such behavior is okay/not criminalized). So, I would like to see courts/legislation require 'provenance' for any PII or similarly important and personal info to ensure that there is an up-to-date, local and legal record of user info, permissions and usages, i.e., every org that has ever used/bought/sold/transferred that info. The provenance bit has been in use for centuries for valuable assets: PII is a valuable asset**, no reason not to have the same care/tracking.

* 'Legally' - there are probably plenty of examples where certain products/services are not legal in the EU but are legal elsewhere on the planet, like pharma/meds, therefore plenty of case law available to figure out appropriate wording/penalties.

** At some point it should be possible to assign a dollar value to each person's PII based on a bunch of metrics. Once this happens, the provenance will become a necessity so that anyone whose PII has been compromised can sue (or gov't can fine) the scummy org for at least that amount to be paid in full, immediately. Maybe liens for PII on all orgs and their senior management too. And, as learned from the fracking industry: absolutely no out-sourcing because out-sourcing allows scummy org execs to hide from the public and from the law.

73:

There's a long history of large orgs relocating when/if they happen to dislike some new piece of legislation in their current geography.

I too will be interested to see how this pans out.

We have the USA trying to unilaterally require that businesses all over world implement sanctions on Iran.

And we have the EU trying to unilaterally require that businesses all over the world implement privacy/data restrictions on any website an EU citizen may use.

Globalization, eh. Fun times.

74:

We have the USA trying to unilaterally require that businesses all over world implement sanctions on Iran.

Isn't the US also trying to ban secondary boycotts (like BDS)? Surely some enterprising US citizen could take their government to task if they do that.

Realistically, this is going to be the usual pointy US foreign policy. Recall that the last lot of "concessions" to Iran was the offer to think about possibly releasing hundreds of millions of dollars if Iranian money that the US has "impounded" and held for more than a decade. Things like that are why companies and countries all over the world will "voluntarily comply" with an new boycott. "nice bank account you got there. Be a shame if it went the way of all that Iranian money".

On that note, Paypal implement the personal version of that - they'll happily freeze accounts and demand whatever they like before releasing your funds. They're not a bank so they're not bound by any local rules your country might have. Good luck.

76:

Seeing this and the previous post, suddenly I wanted to read an Elder God's G.D.P.R. compliance notice. 'Your soul contains information about you. After I consume your soul, I may….'.

77:

I like it. I wish I could use it. :(

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This page contains a single entry by Charlie Stross published on May 18, 2018 11:45 AM.

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