bozho's comments

bozho | 5 years ago | on: Let’s Kill Security Questions

and also, this is some non-obvious practice for people who are not security experts. They answer honestly because that's what they are asked

bozho | 6 years ago | on: Ask HN: What's the best mail hoster for a startup?

Even 10 euro a month per user is nothing - their salary + insurance + taxes is probably 3-4 thousand euro at least, these 10 euro are a statistical error.

We use Office365, because we need Office anyway. We initially used a hosting provider email server, but it's not trivial to get the email DNS configuration right, and you risk going in spam. Even after we got our configuration right, we still had occasional "spam" issues.

bozho | 8 years ago | on: GDPR – A Practical Guide for Developers (2017)

a) companies had 2 years go comply. Furthermore, the guidlines of the European Commission are clear that the process should be gradual - inspect, write recommendations, small fines, bigger fines. Nothing like "20 million in June"

b) the law had to cover a lot of usecases and in order to do that concisely, it may sound vague in places. I also don't like (developers never like uncertainty), but there's established practice already in regulators and courts about what is considered "adequate", "appropriate", etc. I agree it could've been better though.

c) that is happening already, e.g. ICO (the UK regulator) has a pretty good set of guidelines and examples. There's also the process of "prior consultation" where if you are not sure about something, you go ask your regulator for a decision

d) this is exactly what the "proportionate", "adequate", etc. are in for. If you are a small company with 2000 data records, you are not posing a high risk for the rights and freedoms of data subjects and so most of the things are not a strict requirement

bozho | 8 years ago | on: GDPR – A Practical Guide for Developers (2017)

A few clarifications (author here)

1. yes, you are correct, most of the features don't need to be implemented in code and having documented procedures would be sufficient (and that is pointed out in a number of places in the article). However, if you are not a small business or have a lot of users, the time needed to implement the features will be negligible compared to the amount of time needed for handling manual requests.

2. The "legitimate interest" legal basis is harder than it seems and many regulators warn against its overuse. Lawyers in my country are skeptical that regulators will accept legitimate interest in many cases, so "to be on the safe side" they recommend relying on consent. Again, as pointed out in the article, this is up to the legal team to decide.

3. The right to be forgotten is valid even under legitimate interest. Article 17(1)(c) is clear about that - whenever a user objects to their data being processed on the basis of legitimate interest. It is a bit hidden, as Article 17 refers to Article 21 which in turn refers to Article 6, but you can piece the whole scenario anyway.

4. About the best practices - agreed, they are not mandatory under the regulation (as pointed out in the article), but having them in place will demonstrate a higher level of compliance.

bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source

That is irrelevant to the topic. Yes, there are big problems, but they are not fixed overnight. They are fixed slowly and patiently by introducing ever more transparency and safeguards.

bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source

From the electoral code, rough translation: "Independent observers are allowed to verify whether the digital fingerprint of the system in the data centers matches the publicly announced one"

bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source

Actually, we made sure that the e-voting provisions in the new electoral code explicitly require the whole software to be open source. Especially for voting this is mandatory, otherwise there is no trust.
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