Timeline for Is displaying email addresses in an application log file allowed under GDPR?
Current License: CC BY-SA 4.0
13 events
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| Jun 12, 2019 at 21:02 | vote | accept | Titulum | ||
| Jan 29, 2019 at 23:47 | comment | added | deviantfan | @StianYttervik Another example of this are backups: As long as they are kept only for limited time, not removing data from backups in generally viewed as ok. | |
| Jan 29, 2019 at 16:49 | comment | added | schroeder♦ | @StianYttervik depending on the nature of the logs and the reason for processing them, it might not be necessary to remove the personal data from the logs. the extreme example: if you want to record who submitted a RTBF request (especially if you want to filter backups later), then you need to record the person indefinitely. And that's ok in GDPR. RTBF is not a "magic wand" to scrub all references of a person from a system. | |
| Jan 29, 2019 at 8:39 | comment | added | Stian | Hm. I am no expert but is it not also necessary to be able to remove a persons data upon request? You should probably add some way of scrubbing the log without making it useless. | |
| Jan 28, 2019 at 17:57 | comment | added | Robin Whittleton | PII is a phrase in common usage in the states but it’s not used in the GDPR. There, the term is ‘personal data’ which to my mind is a bit wider in scope. | |
| Jan 28, 2019 at 12:34 | history | edited | Steffen Ullrich | CC BY-SA 4.0 |
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| Jan 28, 2019 at 12:34 | comment | added | VLAZ | @pabouk in light of the comment above, I suppose - yes, it's not enough. There is functionally no difference between PII hash and a user ID as they both could trace and profile a user. | |
| Jan 28, 2019 at 12:34 | history | edited | Steffen Ullrich | CC BY-SA 4.0 |
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| Jan 28, 2019 at 12:32 | comment | added | pabouk - Ukraine stay strong | So hash of PII is not anonymized enough because it could be related to the PII unambiguously? | |
| Jan 28, 2019 at 12:28 | comment | added | Steffen Ullrich | @vlaz: Just taking the user id is not necessarily a sufficient pseudonymization. Depending on what you log on activity it might be possible to create a profile for this specific user id and based on this unique profile associate the user id with a real world person. This was for example done with pseudonymized search data released by AOL - see wikipedia for more. Given that it is not known what you log in detail no specific process of sufficient pseudonymization can be recommended. | |
| Jan 28, 2019 at 12:10 | comment | added | VLAZ |
"An alternative is to at least pseudonymize the PII as much as possible, i.e. in a way that the logged data are still usable for you but that no association to a specific user can be done even when having all the logged data." Am I correct in assuming that if you log something like user ID, that is fine? So, if you say user 42 did X that is not going to identify that [email protected] did the thing, unless you also have the database information.
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| Jan 28, 2019 at 11:28 | history | edited | Steffen Ullrich | CC BY-SA 4.0 |
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| Jan 28, 2019 at 9:21 | history | answered | Steffen Ullrich | CC BY-SA 4.0 |