> * I (like most companies) have a variety of unstructured and/or immutable logs. I can't just DROP FROM table WHERE. Is it acceptable to delete this data by waiting a few days for a retention period to expire, or do I have to retrofit deletion functionality in?
In order to be allowed to store PII (even if it's in logs) you need a specific purpose. Why do you put PII in logs? What benefit does the user have?
> * What if the retention period is a week, or a month? What if I've been advised to establish those longer retention periods for other reasons?
If there is a legal requirement to keep PII (for example accounting) you can/must keep it as long as the legal requirement demands. If there is no legal requirement you have to delete PII, there is nothing that trumps that.
> * If a bug is found in the data deletion workflow, is it an undue delay to say we'll tackle it next sprint? Do we need to drop everything and make it a priority now?
If your next sprint starts 1 month down the road the regulator won't be happy. If it's next week and your GDPR doesn't have other gaping holes a reasonable regulator won't bat an eye.
> * Once we've resolved a personal data deletion bug, is it an undue delay to roll it out slowly over a week? Does it matter if this is our standard rollout process, or if there's a risky hotfix process we're deliberately choosing not to use?
Are you playing for time or doing responsible software development? If a regulator thinks you are bending the rules good luck, otherwise nobody will demand of you doing dangerous stuff.
I know, there are a lot of things open to interpretation. But as my lawyer told me: "There are people getting a speeding ticket for 5 above the limit and others who don't. Try to stick to the limit and make sure you are seen as one of the second category."
Under the terms of the GDPR, user benefit is not required. I can log any PII I'd like as long as the user's given consent for it to sit in that log, or for it to be used in some process that reads from that log.
I probably would want to impose stricter rules on myself for the sake of avoiding regulators. But that's part of the problem. It doesn't seem possible to comply with GDPR as such without an army of consultants to guide you; what you have to do instead is invent a stricter regulation and follow that one instead.
> If a regulator thinks you are bending the rules good luck
That's the other part of the problem. A healthy regulatory system needs some way to say "well, you think I'm bending the rules, but I'm actually compliant in this complex way you hadn't considered". If a GDPR regulator just doesn't know much about software development, and thinks that any rollout-induced delay is undue, how do I argue against that?
> Under the terms of the GDPR, user benefit is not required. I can log any PII I'd like as long as the user's given consent for it to sit in that log, or for it to be used in some process that reads from that log.
Read my comment again, it does not say a user benefit is required. What it says is that you need a specific purpose for processing PII. A user can only give you consent for a specific purpose. What is the purpose that results in his PII ending up in an immutable log file? Asking for general consent without a specific purpose does not work with GDPR.
> That's the other part of the problem. A healthy regulatory system needs some way to say "well, you think I'm bending the rules, but I'm actually compliant in this complex way you hadn't considered". If a GDPR regulator just doesn't know much about software development, and thinks that any rollout-induced delay is undue, how do I argue against that?
If you feel you are being treated unfairly you will probably argue through your lawyer. As a technical person I would love it if the GDPR is black and white. It would allow me to know if I comply or not but real life is hardly black and white. So instead of being upset with things I can't change I will just do my best to comply.
I need a specific purpose for processing PII, but that doesn't mean that I need a specific purpose for each individual place that PII ends up going. If my web server or database end up incidentally capturing the data in transit, that's not a violation, any more than it's a violation if I copy the data onto more sheets of paper than are strictly necessary.
You are right and in that case you should also have a process in place to delete the PII from the additional sheets of paper. I'm inclined to keep PII out of logs in the first place but am unsure how to proceed. Either just don't log any data / parameters or implement some kind of whitelist like you would with passwords and other secrets.
I only use keyboards with the english international layout although I'm from Austria and the german layout would be the natural one. Therefore the keyboard layout in the OS is also set to english international. I do this because I program.
And still I'm very happy about the easy access for special characters, because in literally every email I have to use one of ß, ä, ö or ü.
Canvas is not the only option. I'm currently developing a racing game where you can build your own race track in HTML5 with my colleagues for our final university project and we don't use canvas at all.
The whole game is built upon SVG, CSS3 (transform3d) and CoffeeScript and it works pretty fine, even on the iPad which is also the target platform. The limiting factor with this combination is the number of DOM elements. We are currently considering to render our racing tracks as a single image so we can remove the several SVG paths we currently use for this.
If you want to take a look you can find the source on GitHub[1] or play the game[2]. Currently only Chrome and iPad are supported. But that's only because we haven't added all vendor prefixes yet.
You say "In fact, it goes against the very ethos of Hacker News.", do you think your action aligns with the "ethos of Hacker News"?
Do you think it's okay to rip-off something just because you think it shouldn't be invite only?
> There is a difference between taking an idea and a design.
When the idea is the design (as is the case with visitor.js), no there is not. In both cases, it's taking and reimplementing wholesale (but from scratch) the closed product into an open-source one.
Never said the motivation was because it was invite-only, I just wanted something similar so I created it. I've modified it somewhat, is it still a "rip-off"? Let me know how much more I should modify it before it isn't a "rip-off".
If you look at both versions it should be clear what I mean with rip-off. I don't care if you implement the "ideas panel" or whatever yourself.
But if I you take the design and make your version look the same, then it's a rip-off. Yes, you modified it. But please put both versions next to each other and tell me they don't look like each other. As long as you don't have an original design it's a rip-off for me.
I kind-of agree. If someones got a thing where part of their value proposition is "invite only" curation - then that same idea with different or no curators seems to be fair game…
In order to be allowed to store PII (even if it's in logs) you need a specific purpose. Why do you put PII in logs? What benefit does the user have?
> * What if the retention period is a week, or a month? What if I've been advised to establish those longer retention periods for other reasons?
If there is a legal requirement to keep PII (for example accounting) you can/must keep it as long as the legal requirement demands. If there is no legal requirement you have to delete PII, there is nothing that trumps that.
> * If a bug is found in the data deletion workflow, is it an undue delay to say we'll tackle it next sprint? Do we need to drop everything and make it a priority now?
If your next sprint starts 1 month down the road the regulator won't be happy. If it's next week and your GDPR doesn't have other gaping holes a reasonable regulator won't bat an eye.
> * Once we've resolved a personal data deletion bug, is it an undue delay to roll it out slowly over a week? Does it matter if this is our standard rollout process, or if there's a risky hotfix process we're deliberately choosing not to use?
Are you playing for time or doing responsible software development? If a regulator thinks you are bending the rules good luck, otherwise nobody will demand of you doing dangerous stuff.
I know, there are a lot of things open to interpretation. But as my lawyer told me: "There are people getting a speeding ticket for 5 above the limit and others who don't. Try to stick to the limit and make sure you are seen as one of the second category."