Re: F30: System-Wide Change proposal: DNF UUID

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On Mon, Jan 07, 2019 at 10:00:25PM -0500, Matthew Miller wrote:
> On Mon, Jan 07, 2019 at 11:09:48PM +0100, Kevin Kofler wrote:
> > Please no! This is an inherent privacy violation. I hate software doing this 
> > and I always opt out of it. I find it especially worrying that Free Software 
> > is now doing this more and more often, this used to be something only 
> > privacy-violating proprietary software would do.
> 
> Since there is no personal information attached, I don't see how on the face
> of it this is a privacy violation. I want to take this concern seriously,
> but I need more to go on than "this is inherent". Can you elaborate?

I'm not a lawyer, but GDPR is something that affects all of use. Going
by the wiki page and GDPR announcements from European Commission:

Scope:
> The regulation applies if ... the data subject (person) is based in the EU
So Fedora obviously falls under the scope of GDPR.

> personal data is any information relating to an individual ... a computer's IP address.
I an IP address qualifies as "personal data", then an installation UUID does too.

Lawful basis for processing:
> Unless a data subject has provided informed consent to data
> processing for one or more purposes, personal data may not be
> processed unless there is at least one legal basis to do
> so. According to Article 6, the lawful purposes are:
> (a) If the data subject has given consent to the processing of his
>     or her personal data;

(b)-(e) obviously don't apply

> (f) For the legitimate interests of a data controller or a third
>     party, unless these interests are overridden by interests of the
>     data subject

We could argue [1] that reliably collecting the number of individual
installations is a "legitimate interest", for example because it
allows us to decide what parts of Fedora are most used and direct our
efforts there. I think it's pretty obvious that knowing the number of
users is a valid interest for any software project. Then we could use
point (f).

Otherwise, we have to use point (a) which is only satisfied by an clearly
worded, and specific, opt-*in* dialogue.

[1] https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/legitimate-interests/what-is-the-legitimate-interests-basis/

Zbyszek
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