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> Telemetry contains personal data by definition.

No. Please look up the definition of "telemetry" and "personal data". The latter always refers to an identifiable person.




Virtually all anonymization schemes are reversible, so “identifiable” isn’t carrying any weight in your definition.

“Person” isn’t either, unless the software knows for sure it’s not being uses by a person.


By your definition, all data is PII.


Many corporate privacy policies per their customer contracts agree with this. Even a single packet regardless of contents is sending the IP address and that is considered by many companies to be PII. Not my opinion, it's in thousands of contracts. Many companies want to know every third party involved in tracking their employees. Deviating from this is a compliance violation and can lead to an audit failure and monetary credits. These policies are strictly followed on servers and less so on workstations but I suspect with time that will change.


I can only repeat myself from above: it's about what data you store and analyze. By your definition, all internet traffic would fall under PII regulations because it contains IP addresses, which would be ludicrous, because at least in the EU, there are very strict regulations how this data must be handled.

If you have a nginx log and store IP addresses, then yes: that contains PII. So the solution is: don't store the IP addresses, and the problem is solved. Same goes for telemetry data: write a privacy policy saying you won't store any metadata regarding the transmission, and say what data you will transmit (even better: show exactly what you will transmit). Telemetry can be done in a secure, anonymous way. I wonder how people who dispute this even get any work done at all. By your definitions regarding PII, I don't see how you could transmit any data at all.


By your definitions regarding PII, I don't see how you could transmit any data at all.

On the server side you would not. Your application would just do the work it was intended to do and would not dial out for anything. All resources would be hosted within the data-center.

On the workstation it is up to the corporate policy and if there is a known data-leak it would be blocked by the VPN/Firewalls and also on the corporate managed workstations by IT by setting application policies. Provided that telemetry is not coded in a way to be a blocking dependency this should not be a problem.

Oh and this is not my definition. This is the definition within literally thousands of B2B contracts in the financial sector. Things are still loosely enforced on workstations meaning that it is up to IT departments to lock things down. Some companies take this very seriously and some do not care.




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