Version 0.16.47

[Floaf]

- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);

- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

This is like the path to the logfiles, the factorio team does not need to know the path for debugging purposes and if they do not collect it, they do not risk collecting the username that can be personal information. The less data you collect, the less data can be inaccurate.

- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (‘storage limitation’);

This is the retention time. Since you have to delete/anonymize data when not needed for the service you provided (and the user has agreed to), the data that need deleteion/anonymization has to be identified and therefore you have to be stored in a way that permit this.

- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).

As data collector, you have to write down what data you collect, and why. this is a one time thing, and you do not have to ask permission for data you are required to collect by law in your country. You DO have to inform your clients, pupils, website visitors, etc WHICH data you collect, and for what purpose.

I Think they refer to data that has to be kept ny law. That data cannot "accidentally disappear". Like ISPs that have to keep logfiles of their users IPs for helping police find people doing illegal activities (like some types of file sharing etc.).

[youdoomt]

I was thinking of this:
Every installation of Factorio would generate random string, and this string would be included in the log. Every time you install, the string would be different and there would be no way for us to know who is it related to.
But if we saw 10 different crashes with the same random string, we would know it is the same user, we could even automatically sort the crashes by it, so we would know how many crashes/unique users had the problem.

Would this be problematic in any way?

This is mainly, because the top of our crash logs is now usually one user with some hardware/system problem doing a lot of crashes.

I now believe that there is nearly no way to collect such an information without it being 'personal data':

Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

Your current idea will be an 'online identifier', just like a cookie ID is an online identifier.

and since:

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

there would be no way for us to know who is it related to.

This perspective is also taken into account:

The principles of data protection should apply to any information concerning an identified or identifiable natural person. Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information should be considered to be information on an identifiable natural person. To determine whether a natural person is identifiable, account should be taken of all the means reasonably likely to be used, such as singling out, either by the controller or by another person to identify the natural person directly or indirectly. To ascertain whether means are reasonably likely to be used to identify the natural person, account should be taken of all objective factors, such as the costs of and the amount of time required for identification, taking into consideration the available technology at the time of the processing and technological developments. The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes.

But I'm a bit unsure about this part.


other links:

• https://ec.europa.eu/info/law/law-topic ... al-data_en
  https://www.gdpreu.org/the-regulation/k ... onal-data/

[Klonan]

So are trains completely back to normal now??

I take it that's a no then??????

They are alright

[Gergely]

They are alright

...

......

[eradicator]

The extent to which the windows username is personally identifiable data depends strongly on how you interpret the law text.

More like...how the judge interprets it. And that's often inconsistent between judges and/or courts. Better safe than sorry.

[youdoomt]

The extent to which the windows username is personally identifiable data depends strongly on how you interpret the law text.

More like...how the judge interprets it. And that's often inconsistent between judges and/or courts. Better safe than sorry.

It actually depends of what the username is, or more precisely who or what owns the computer.

[ratchetfreak]

-snip-

you are forgetting about this bit

This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

as long as that random string is only used to transmit crash logs and those logs are further kept clean then there is no issue.

[youdoomt]

This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

as long as that random string is only used to transmit crash logs and those logs are further kept clean then there is no issue.

I'm only arguing that the random string is 'personal data', so I don't understand what you mean about:"then there is no issue.".

Unless someone comes up with a bulletproof argument, I strongly believe, that they have to follow the rules of GDPR, if they want to implement this.



Sidenote:
This forum haven't updated and given notice by their processing of 'personal data'. So they should properly get that updated before they get fined.

[Gergely]

This forum haven't updated and given notice by their processing of 'personal data'. So they should properly get that updated...

WHO CARES?!

Like... I don't. Enough is enough!

[Oktokolo]

I'm only arguing that the random string is 'personal data', so I don't understand what you mean about:"then there is no issue.".

A random string is not personal data. It becomes data that could be used to identify a person if it is associated to data identifying a person (if stored together with an email or ip address for example).
There is no problem in transfering and storing that random installation ID together with the crash logs.

Unless someone comes up with a bulletproof argument, I strongly believe, that they have to follow the rules of GDPR, if they want to implement this.

The use of random purpose-bound identifiers is exactkly how you implement something like what Wube needs for their crash log collection in conformance with GDPR.

This forum haven't updated and given notice by their processing of 'personal data'. So they should properly get that updated before they get fined.

They will not get fined that fast - not for running a small web forum without a proper data processing policy. It is not like everyone would now go on hunting for GDPR violations and fine random people to death. That is just not how it works.
Someone may complain to a regulatory agency then that agency would contact Wube. Then Wube would probably still have some weeks to fix whatever needs fixing. Only if they would then refuse to comply there would be the possibility for a fine - and even then it would be a reasonably small one at first. They wouldn't bomb anyone out of business just for the sake of it. Remember: GDPR is made to be used against Facebook and Google. And that is the sort of target, agencies will concentrate on for for now.