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Orinoco - 2018-03-31 13:33:41 UTC - Parent #

Not really, I periodically update the encryption/hashing code as updates mature.

But since you mention it...

For those that don't know (& I didn't until this week) the GDPR is the General Data Protection Regulation. It affects all services that serve EU citizens & comes into force on the 25th of May 2018.

It has 7 core features. My understanding of them & what I need to do between now & May are listed below:

Breach Notification

If we have a security breach & your personal data is exposed I have to tell you.

I have always intended this to be the case so no change here. We've never had a breach & easily 90%+ of the work I put into the Edge is ensuring that we never will. I have several automated processes monitoring for problems. I will know if something has gone wrong within 24 hours at the very longest.


Consent

Consent to use your data must be clear & unambiguous.

The important bits of personal information that are used on the Edge are:

Your Email address.

The timezone you set on your settings page used to be used to format times on forum posts, but is now only used to set a default location when you visit map pages. I'm probably going to do away with this altogether.

If you have selected the 'clubs near me' option for your home page we store some coordinates (which of course you haven't used to exactly pin point your house). As the page says: "This location is not publicly displayed and is not shared with other users."

When posting to the forum it does state that your posts are thrown to the mercy of the public. I need to put this message everywhere.


Right to Access

You have the right to access all the data that relates to you.

You pretty much already have this. All your private information is visible on your settings pages, all your public information is accessible via your profile page. I do need to make more of this downloadable though for the Data Portability bit of the regulation.

Stuff that you may not know about:

1. If you report a problem on meta talk I also record your browser's UA string (name & version of the web browser you are using). This is only visible to me & I often need it to tell Void to stop using his iPad. Need to adjust post form to make this explicit & opt in.


2. At any given time I do have 5 days worth of Apache server logs which is a standard feature of webservers. This is a record of every page visit. It includes the ip address, date, time, full web address, the referring page if known & the browser's UA string. These logs are scanned daily against an extraordinarily complex whitelist to see if any malicious requests have got through.
   
   This data is mostly impersonal. At no point is an ip address saved against anything directly tied to an account, after 5 days there is no record of your ip address (aside from point 3 coming up next). I don't know who an ip address belongs to unless you log in & post something in which case I can find out your ip address by looking up the post added to the database at the time the request was made. I used to do this quite a bit to diagnose issues but the Edge is very robust now, I can't even remember the last time I did this.
   
   The regulation suggests that I should provide this data & I could modify my log verification code to pull out all requests from a specific ip address. However, ip addresses can be forged. Nor is an ip address guaranteed to be a single person. Two people in the same household or any number of people using a computer at a convention internet cafe or, "can I borrow your phone because my battery has died" for example could all share the same ip address. So I don't think I will be making this available as a feature but as something you can request from me. I can pull out all requests from an ip address & possibly work out if the requests have been made from multiple accounts then try to decide which bits relate to you. Although first you'll need to convince me that the ip address you want me to look up was genuinely under your control in the first place, & I wish you the very best of luck with that.


3. If you see a red warning message, the date, time, ip address & that message is recorded in a log file. I use these to pick up trends of what people want to enter into forms that they think the Edge should be able to handle. As trends emerge I alter the code to handle the new data or change forms to enforce/encourage the type of data I want to handle. For example, most recently I gave up on trying to enforce unique hashtags between clubs, events & groups; hashtags are not used frequently enough to really matter & most of the time it was just penalising a reoccurring festival for trying to recycle last year's hashtag. Once I've made a change or fixed the problem these logs are cleared. These logs are similar to the access logs already mentioned but because they generally contain info accumulated when someone has tried to post something this is mostly info that can be linked to an individual account. I will start recording the UserID where applicable so that I can automatically pull out which messages apply to which users.
   
   So ironically I will need to start recording more information in order to comply with the GDPR!

This is all closely related to...



Data Portability

You should be able to download your data in a machine readable format so you can move to another service.

The only other service that you could move to is https://juggling-records.com & we've had that in place for years! This is related to the Right to Access above, pretty much there. I just need to make it easier & all in one place.



Right to be Forgotten

You have the right to have all your data deleted.

Pretty much already have this. At the bottom of your settings page is a link to disable your account which will delete almost all of your data. To comply with the new legislation I will also need to purge forum posts (gah! but easy enough) & record data (not quite so easy as someone else can post a passing record that involves you so exactly whose data am I deleting?).



Privacy by Design

This section reads like the vague spiel of a consultancy firm. Basically I need to design the system to use as little data as possible & expose that data as little as possible. I think I've already done this. You don't need an account to browse the Edge there are no members only sections. To create an account you need all of three bits of information: username, password & email address. I've also pretty much persuaded myself to make the password reset function optional, in which case I won't even need your email address.



Data Protection Officers

Organisations need to appoint a DPO to oversee compliance with the GDPR & be available to the public & the powers that be (which is the ICO for the UK) to deal with any issues.

I'm not a company or a public authority so this doesn't really apply. Regardless I'm doing my best & the contact form is always open!