bozho | 4 years ago | on: Bulgaria's new eGov minister is a software engineer
bozho's comments
bozho | 4 years ago | on: Bulgaria's new eGov minister is a software engineer
bozho | 5 years ago | on: Let’s Kill Security Questions
bozho | 6 years ago | on: Ask HN: What's the best mail hoster for a startup?
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 | 7 years ago | on: Blockchain – what is it good for?
bozho | 7 years ago | on: Estonia sues Gemalto for €152M over ID card flaws
bozho | 8 years ago | on: Ask HN: Cookies vs. JWT vs. OAuth
bozho | 8 years ago | on: GDPR – A Practical Guide for Developers (2017)
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)
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 | 8 years ago | on: Show HN: LogSentinel, blockchain-inspired secure audit trail service
bozho | 8 years ago | on: Show HN: LogSentinel, blockchain-inspired secure audit trail service
bozho | 8 years ago | on: Show HN: LogSentinel, blockchain-inspired secure audit trail service
bozho | 8 years ago | on: Show HN: LogSentinel, blockchain-inspired secure audit trail service
bozho | 9 years ago | on: I stopped contributing to stackoverflow, but it's not declining
bozho | 9 years ago | on: Pokémon Go Is Not Good Enough
bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source
bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source
bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source
bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source
bozho | 9 years ago | on: Bulgaria Passes a Law Requiring Open Source