GDPR
GDPR
Drive we are so privacy focused here. What is to prevent myself or anybody out there, from starting to report individual instances of GDPR and CCPA.
No lemmy insurances are complying with national privacy laws and nobody is talking about it at all.
Geez, check out OP's comment history...
OP is nothing more than a corporate boot licking troll, if would seem. That makes this post concern trolling.
Hey OP, if you actually cared about this issue, you'd be trying to help people. But you're not helping anyone anywhere on the network.
You clearly don't want to be here. So, log off and just don't come back.
Never seen so many negative points
Mutant might see that as a challenge.
Yikes, you're right. Definitely corporate troll. Either that or he's just so deep in his own cynicism he can't help himself.
Definitely dealing with a lot of copium around the reality of running web services.
Yep, nobody is talking about it at all...
🤷♂️ seems pretty buried with the current UI. In general most users seem to think this place is actually more private than a reddit or Facebook.
It is for the sole reason that it doesn't prevent any form of fake profiles or multi accounting.
There is even an argument that a rando profile with a fake mail adress that's not used anywhere else is not traceable to you, since the other information (IPS, Session data, etc) that's necessary to do that is not federated.
Have been asking this myself lately.
People always seem to get defensive about this topic, but if an instance gets challenged on a GDPR investigation it could have a huge fine associated to it.
It is good to have this sorted out, so instance owners don't enter a life changing financial risk.Currently we probably are too small and fly under the radar, but this could become a big problem as the fediverse scales.
Issues I wonder about:
- How safe is the Fediverse? Is there a way for a federated instance to misuse the user data? Or can such activity be detected and cause a defedaration.
- How easily can all user data be deleted if a request comes in to remove all personal data? Wouldn't that request have to be extended to all instances your instance is currently federated with?
- Instances probably wouldn't be able to handle a bad actor (for example Meta, or spez) that decides to start a mass request attack.
- Corporations have lawyers that deal with this stuff, I don't feel like most instance owners have the same kind of protection here.
Totally agree, there is really valuable discussion to be had and collectively it needs to be resolved and approached holistically and consistently across as many instances as possible. Just because you're someone running a tiny server doesn't mean you can't get absolutely dragged over the coals for breach and or non-compliance.
Even things like reporting incidents and breaches of the service for each instance - it is very unlikely tiny servers can or will comply with so many aspects of GDPR.
I think the fact that someone could maliciously (or actually, genuinely) report instances now using a relatively straightforward process should be grounds to get the wheels moving on this really!
For example, you can report non-compliance with cookie information in a one page form here: https://ico.org.uk/make-a-complaint/cookies/report-cookie-concerns/. The process for consumers to kick off a potentially serious enforceable action is very straightforward.
Disclaimer: I have no law degree and everything in this post is speculative.
After reading up on GDPR (https://en.wikipedia.org/wiki/General_Data_Protection_Regulation) it deals with the transfer of personal data to entities outside the EU or EEA for processing. The definition of personal data would be the main point to see if/how GDPR is applicable to lemmy instances. (https://en.wikipedia.org/wiki/Personal_data)
Your IP address and EMail address could be classified as personal data from my point of view. But this won't be shared or processed outside of the instance as far as I can tell. If your username and associated posts are classified as personal data I can't say, but there seems no connection of these to your IP or Mail outside the instance. According to this TechDispatch (https://edps.europa.eu/data-protection/our-work/publications/techdispatch/2022-07-26-techdispatch-12022-federated-social-media-platforms_en) the instances still must adhere to GPDR, but as there is not much or no processing of personal data taking place this should pose no issue.
All of this is based on a bit of research, so please enlighten me if I made any mistakes.
In the UK a screen name is an identifier. See ICO here. I am in the UK. Therefore combined with other data being collected, e.g. IP. Lemmy and instances I interact with are handling personal data. If it is transferred between instances when I search or view content from one instance to another, there are GDPR implications.
Here is the information I have on your user ID as an operator of a remote instance.
1: Your username and home instance (and a separate link to your profile page on your home instance)
2: Your avatar
3: Your about info
4: Date/time of your last activity (but that I think will be the last time you were seen by my instance, interacting in a community I also have here), so not shared really.I took a look at the json returned from your home instance, and again the info is profile page, username, information required for communication between instances with the only PII present being the username, the about and an icon and image.
Here's why I'm going to say this isn't likely to be a problem as such. This is the same as on reddit, if I look at a post a user makes I can click on the user and get access to this level of public information. Also under GDPR and DPA based on advice from the ICO data sharing isn't forbidden, but the minimum required to fulfil the function of that sharing should be sent. I think the above data meets that. There isn't information we don't need to work a distributed network like this.
I think the point about making a privacy policy visible is a good one. It should make it clear how the network works, and what kind of information is shared with federated instances (and also available to the public, the user query is publicly available). But the data that is federated is the same as is publicly available.
Now I do feel like there's the scope for a lot of manual work. For example, federation sometimes means that edits/deletes don't make it. It can be caused by problems on both sides of the connection. So if you want all your data deleted. Sure I could delete all posts and your user info here. And even make requests to the home instances that they delete them too. But, some might remain on remote instances, and I don't know who would be responsible for that. Some grey areas remain.
I agree, there is definitely work to be done regarding compliance.
but this won't be shared
How do you know that? No registered entities, no policies, no assurance what so ever.
But this won’t be shared or processed outside of the instance as far as I can tell.
At least use the whole sentence when quoting to avoid confusion.
Looking through the activityStreams definition it seems only Usernames are shared (https://www.w3.org/TR/activitystreams-core/#actors), which is already personal Data according to another comment (https://lemmy.world/comment/929906)
Permanently Deleted
There is no taking back what you post on the internet, but with activity pub it’s almost guaranteed to not have been processed.
This is a bug, not the intended design with federation.
Pretty sure your deletion issues was due to the federation issues that Lemmy was experiencing before the latest round of patches. I've had issues where federation didn't even publish my comment to other instances.
I am sure once all the bugs get ironed out, these deletion issues will go away.
This is one reason I think there needs to be a public issue tracker and backlog.
If issues deleting data is a known issue, that means it is known Lemmy / instances cannot comply with right to be forgotten requests. I think there are also rules around informing people who have made requests why you are not taking action, how they make a complaint (in UK this is to the ICO), and that they have a right to get this enforced though legal proceedings.
It feels like it's not just some elements not complying, it's like a stack of things that just goes on and on!
Permanently Deleted
The issue for lemmy is the same as mastodon
The Mastodon.social privacy policy covers a lot of this, https://mastodon.social/privacy-policy
This is the least every lemmy site should have
That makes no mention of GDPR or the ability to have data deleted.
It does, and this is to comply with GDPR
You can request and download an archive of your content, including your posts, media attachments, profile picture, and header image.
You may irreversibly delete your account at any time.
It does
You can request and download an archive of your content, including your posts, media attachments, profile picture, and header image.
You may irreversibly delete your account at any time.
If this server is in the EU or the EEA: Our site, products and services are all directed to people who are at least 16 years old. If you are under the age of 16, per the requirements of the GDPR (General Data Protection Regulation) do not use this site.
It does
You can request and download an archive of your content, including your posts, media attachments, profile picture, and header image.
You may irreversibly delete your account at any time.
If this server is in the EU or the EEA: Our site, products and services are all directed to people who are at least 16 years old. If you are under the age of 16, per the requirements of the GDPR (General Data Protection Regulation) do not use this site.
How are instances not complying?
Where are the compliance pages? That's literally step 1.
Yes, the only thing some instances don’t have. My home instance has it.
Which "nation" are we talking about and which laws do you mean specifically?
Can you provide specific and detailed examples
This is just at a really high level. Take for example https://lemdro.id. I am in the UK.
- I do not get cookie information / consent
- How do I make a SAR request, it isn't stated
- What is their data retention and privacy policy, it isn't stated
- How do I make a data sharing request as a member of law enforcement or government
- How is data processed if I am under 16/13
- Is data transferred from an EU to non-EU server if I search their content from another instance? Are the correct controls and risk assessments in place
- If I delete my .id account under right to be forgotten, how is my request propagated between other instances to ensure my data isn't retained somewhere on another instance which has pulled the data
- If I use an account from another instance and post an image on .id, and then delete my account, is the image I posted deleted from their server and backups etc
GDPR is very serious and an absolute minefield. I am pretty sure Lemmy and individual instances are not compliant, and I am not sure they can be fully - it may have to be on a best-endeavours basis. Be interesting to see how that holds up under a challenge.
I actually question whether GDPR is up for the task of distributed systems like this.
Like, if you put in a right to be forgotten request to your host server, it's not at all clear that they're responsible for the copies of your content that are being hosted elsewhere, any more than asking a news website to remove your personal information from an article requires them to also hunt down anyone else who has copied and spread the story to remove it, too.
Different Lemmy websites are independently owned and operated, and your local admin holds no authority over other admins. They can request deletion on your behalf, if that's a legal requirement, but they cannot compel action. I'm not even sure they can act as your proxy, given that there's no formal relationship between admins.
If I delete my .id account under right to be forgotten, how is my request propagated between other instances to ensure my data isn’t retained somewhere on another instance which has pulled the data
There's no way GDPR can tell we hosts they are responsible for other platform's copy of data, right? Wouldn't that mean Twitter has to remove tweets from every news article that makes copies, for example, if someone deleted their account under that right?
Holy shit that is quite a lot
Can you point my to where the GDPR policy for lemmy.world is?