This is an opportunity for any users, server admins, or interested third parties to ask anything they’d like to @nutomic@lemmy.ml and I about Lemmy. This includes its development and future, as well as wider issues relevant to the social media landscape today.
Note: This will be the thread tmrw, so you can use this thread to ask and vote on questions beforehand.
I asked in the other thread about GDPR.
Nobody thinks it’s very interesting but if instances don’t follow gdpr, the entire network is at risk of legal consequences.
So please bring this up, even though it’s not very fun.
Neither @nutomic@lemmy.ml or I are too familiar with the GDPR, so we don’t know everything that it requires. Lemmy doesn’t do any logging of IPs or other sensitive info, but of course instance runners could be doing their own logging / metrics via their webservers.
We have a Legal section under admin settings, that’s an optional markdown field, that can probably be used for it. We’d need someone with GDPR expertise though to help put things together. Lemmy is international software, not european-specific, so we have to keep that in mind when supporting GDPR.
As a person who oversaw the implementation of GDPR in a large software house (which wasn’t EU specific, but had to in order to operate legally in the EU), the requirements were:
- Allow users to request data deletion or a copy of their data.
- If the former, delete all data of their data on the server, send it to them, and then (this was the important part) forward the data deletion request to every single partner we were working with.
For us, this was multiple ad companies. We had to e-mail each one, ask them about their GDPR implementation (most of them were somewhere between “we’re thinking about it” and “we have an e-mail address you can send something automated to and we’ll get to it sometime within the next month”), and then build an automated back-end system to either query their APIs for automated deletion, or craft/send e-mails for the more primitive companies.
As far as the data being deleted, it was anonymized IDs that were tied to their advertising IDs from their mobile phones. I used to try and argue that “no, it’s anonymous” - but we also had some player data (these were games) associated with that, so we ended up just clearing house and deleting everything on request.
So, legally, this means every instance - in order to be GDPR compliant - would have to inform every instance it federates with that a user wants their data deleted. If you’re not doing that, you’re not fully compliant.
Kind of shitty, but that’s how it went for me. (this was back when GDPR was first being released)
Edit: Also, the one month thing was relevant: you have 30 days to delete GDPR stuff after receiving a data clear request. I don’t recall what the time was for a “see my data” request. Presumably, though, on Lemmy the latter is superfluous as all your data is already present on your profile page. An account export option would be enough to satisfy that.
There a different levels of personal data but a unique identifier for a user is one of them because it allows linking information together about a single person, and from there you can try to identify the real person. So an option would be to overwrite all the occurrences of this identifier with random data so you can’t link data together anymore, as long as it’s not also personal data.
So, I wonder if Lemmy instances would be responsible for the instances that federate with them. It’s my understanding that the Lemmy instance doesn’t send the user’s data to other instances, rather it is just posted, and the other instances copy it onto their local instance.
It’s almost like those reddit services that would show deleted content. A user can delete their profile on Reddit, but Reddit isn’t required (that I know of) to go to these services and make sure the user’s data is being wiped out.
Im not a lawyer so I dont know about GDPR. Do you know how similar platforms such as Mastodon handle it?
Hard to say exactly what Mastodon does, but mastodon.social’s privacy policy should give you some direction in how they handle data: https://mastodon.social/privacy-policy
As mastodon.social is based in Germany, they will know about GDPR and have to follow it to the letter.
That sounds like its something for instance admins to handle, nothing we as developers need to care about. Maybe we should add a privacy policy for lemmy.ml but thats it.
That’s what I thought too until I looked it up. It applies to individuals as well.
If an individual runs a web server and processes personal data of individuals within the European Union, then they are subject to the requirements of GDPR. GDPR applies to anyone, including individuals, who processes personal data of EU residents, regardless of whether they are operating as a business or on a personal basis. It’s important for the individual running the web server to comply with GDPR’s data protection principles and obligations to safeguard the personal data they process.
As someone not residing in the EU, I don’t see how they could possibly enforce that. Best they could do is block my instance I suppose. Have they done that for any small site?
I mean, I would delete/provide all data of any user who requests me to do so for themselves. But I’m likely not following every facet of the GDPR.
