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korlja | 3 years ago
We did something similar for a project, which got approved by the relevant data protection officer: hash(IP + daily secret) as an identifier in the logs. This will be used to count unique visitors, the wraparound at 24:00:00 didn't matter to us. The daily secret is just a random number that our one (small setup) application server generates each day. It is never written out to disk or database, so an appserver restart also recreates that secret, it is strictly kept in RAM. That way, we could argue that, barring extreme measures like attaching a debugger to get the secret, we technically prevented deanonymisation.
But that was just a small-scale project, has never been tested in court and the usual YMMV, IANAL, ...
Edit: I think some webservers can be configured to do something similar
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