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Changes between Initial Version and Version 1 of Ticket #43492, comment 42


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Timestamp:
04/05/2018 01:55:05 PM (3 years ago)
Author:
DavidAnderson
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  • Ticket #43492, comment 42

    initial v1  
    1 @robscott Is there really still an open question that a large number of website URLs will be classified by the GDPR as PII? The GDPR says?
     1@robscott Is there really still an open question that a large number of website URLs will be classified by the GDPR as PII? The GDPR text says:
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    33> ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly
    44
    5 I don't see any ambiguity there. They've written "directly or indirectly" to clarify that it doesn't matter what means are being used to perform the identification (i.e. we can't say "ah, but we'd have to manually browse their website to do it, and that's hard to automate") - they've covered that. They don't specify particular types of data - once *any* of the data can lead to identification, *all* the data is then PII ("any information relating to").
     5I don't see any ambiguity there. They've written "directly or indirectly" to clarify that it doesn't matter what means are being used to perform the identification (i.e. we can't say "ah, but we'd have to manually browse their website to read their 'About' page to do it, and that's hard to automate") - they've covered that. They don't specify particular types of data - once *any* of the data can lead to identification, *all* the data is then PII ("any information relating to [a person]").
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    7 But on your major point - I'm very interested in that too. How does wordpress.org storing (assuming I've understood rightly) your number of users, and site URL, and various other things, and explicitly linking those to your site URL, and storing it all, without anonymization, do anything for security, given that the security updates mechanism in WP is pull-based and has no facility at all for push-based?
     7But on your major point - I'm very interested in that too. How does wordpress.org storing (assuming I've understood rightly) your number of users, and site URL, and various other things, and explicitly linking those to your site URL, and storing it all, without anonymization, do anything for security, given that the security updates mechanism in WP is pull (polling) based and has no facility at all for push-based? (The 'automatic' updates on core and sometimes on plugins are still pull/polling based).
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    99The GDPR is explicitly designed to force granularity - it's not a by-product, it's one of their core aims. If you get piece of data A as something necessary for purpose X, then you can't process it for purpose Y - that needs separate/sufficient justification before your allowed to touch it, even if it's stored on your servers and you got it legitimately for purpose X. On my understanding of the WP updates mechanism (code which on the client side I've studied and interacted with at some length), the site URL is never used in the updates response at all. And things like the number of registered users certainly make zero difference to the returned results. So things of that sort surely need explicit opt-in, even if other things are deemed essential to the normal operation of WP (on which I don't have a specific opinion).