[GNC-dev] GDPR and gnucash as a project
jralls at ceridwen.us
Tue May 22 10:35:24 EDT 2018
> On May 22, 2018, at 6:02 AM, Geert Janssens <geert.gnucash at kobaltwit.be> wrote:
> Yesterday John raised some concerns about GDPR compliance of the gnucash
> project itself.
> This is a different question from the one Mike Evans asked in April this year
> about GDPR compliance by people *using* gnucash.
> This requires some thought as the GDPR has many aspects.
> The essence of the GDPR (global data protection regulation) is to regulate the
> processing of EU citizen's personal data.
> The first question this raises is which personal data does the gnucash project
> process ? So far I have come up with:
> - e-mail addresses on the gnucash mailing lists
> - user accounts in bugzilla
> - user accounts in our wiki
> - user accounts on Uservoice
> The above are pretty clear. There are others that are less clear to me whether
> they constitute personal data or not:
> - the actual messages people send to mailing lists and which are stored in a
> public archive
> - the actual comments on bugs
> - the actual page edits in wiki
> And also what about things like our irc channel ? Does that fall under
> processing personal data ? We don't really run the irc channel, we only use
> it. But on the other hand we do publish irc logs. Does GDPR apply to those ? I
> can't tell really.
> And the same question could be asked about our code itself in a way. Does a
> code contribution represent personal data ? Each commit logs an e-mail address
> of a committer which can't easily be removed.
> Once we have established what constitutes personal data we need to formulate a
> third parties are involved (think github, uservoice, travis-ci, our social
> media presence,...).
> An open source project is a bit in an odd situation because we do almost
> everything in public so there's very little being kept private. We publish
> archives of our mailing list conversations, irc logs, commits and so on. We
> have to inform our users of this in a clear manner. The good thing is we only
> do keep the absolute minimum amount of information to function: a username
> (which can be an e-mail address) and a password is usually sufficient. Unless
> the message content also falls under personal data.
> We also require explicit consent to use the personal data. We're reasonably
> good in this respect as for all services we offer we require the user to opt-
> in. We will never use for example mail addresses gathered from bugzilla user
> accounts to automatically enroll the same people in a mailing list. We
> probably should more clearly indicate what people subscribe to in each case
> while they are registering. So when registering for a mailing list, it should
> be pretty clear that anything the person contributes will end up on a public
> web page. The same goes for all other services we offer and make use of.
> Next a person should be allowed to make corrections to the personal data we
> were provided with and "the right to be forgotten". For user accounts in the
> various services we offer this is not really a problem. Most of these do allow
> the user to change passwords, user names or e-mail addresses. However if the
> message content is also part of private data it becomes much harder. In that
> case the question becomes whether a user can request a mail message to be
> removed from our mailing list archive. I have no answer to this.
> Next there is the requirement to protect children. I don't know for sure if
> this applies to us. If it does our registration processes should ask a minimum
> age and require consent of a parent or equivalent in order to continue with
> the registration. This is mostly mentioned in the context of social networks.
> But as we publish all communication in public it may apply to us as well.
> And finally in case of data breaches we should inform the affected people of
> this. Again one I don't know exactly how to deal with.
> This mail is meant as a kick-off to start thinking about this. Any feedback is
> very welcome.
Some more considerations:
Uservoice data lives on Uservoice’s servers, not ours, and so GDPR compliance there is their problem.
We have copied from Gnome’s BZ a bunch of names and email addresses for reporters, commenters, and developers on GnuCash bugs without those people’s permission. The GDPR permits collecting information without permission for “business necessity” so I think it’s legal;
it’s easy for a user to change their name and email in BZ, or for us to do so for them, meeting the “right to be forgotten” requirement.
IRC includes IP addresses, which the GDPR explicitly mentions as personal information, in “joined” messages, and those get logged. ISTM those messages aren’t important as they’re not part of the conversation and we could easily stop logging them delete them from the existing logs.
We collect user names and emails for authenticating new users and transmitting their initial credentials. AFAIK we’re done with them after that; I don’t even know if the wiki retains them.
The “right to be forgotten” is pretty incompatible with Git: It includes the contributor’s name and email address in the commit and it becomes part of the blockchain. Removing it requires rewriting the blockchain which invalidates every other clone of the repository. Anonymizing contributions also makes it impossible to trace copyrights since we don’t require transfer of copyright and anyway have no entity to accept the transfer.
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