Hacker Newsnew | past | comments | ask | show | jobs | submitlogin

See my edit. There's conflicting information on this. A dynamic IP, for example, isn't directly related to or relatable to a specific natural person without other context.

But even if that's the case, if you don't tie the pseudonymous ID to the IP, it isn't personal data. As far as I can tell, the transfer rules you reference are about transferring data out of the EU, and can be summarized as "you can't transfer data to a non-EU country and then process it in a way that violates the GDPR". Article 46 notes that transferring data is fine as long as appropriate safeguards are in place[1], and article 47[2] defines what constitutes those safeguards (in general, contractually/legally binding agreements with appropriate enforcement policies).

This goes back to what I said before: The theoretical capability to do noncompliant things doesn't make a system GDPR-noncompliant. You have to actually do noncompliant things to not comply.

[1]: https://gdpr-info.eu/art-46-gdpr/

[2]: https://gdpr-info.eu/art-47-gdpr/



Guidelines | FAQ | Lists | API | Security | Legal | Apply to YC | Contact

Search: