Re: RFC 6302: "Internet-Facing Server Logging": No Word about Privacy?

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Hannes Tschofenig wrote:
> 
> Yes, I understand what the document is trying to say. The insight
> that the presence of NAT also requires you to log the port number
> is certainly not a new insight. 
> 
> My worry with the document is that if you have to give someone who
> deploys services such trivial information (as it is done with the
> draft) then it is quite likely that they also need to be told
> something about privacy. As the discussion around Web tracking
> shows there is little understanding of meet the privacy
> expectations of regulators. 


What this document describes will often be illegal in Germany,
and you risk a fine up to 300000 Euro for doing it on an
"Internet-Facing server".


3.5 years ago there was an illegal data privacy violation of a technically
different kind that made the german news:

 http://content.stuttgarter-zeitung.de/stz/page/1629475_0_9223_-reinigungsrechnung-an-kundin-volksbank-macht-rueckzieher.html

It was about some smelly mess (allegedly dog shit) on the floor near a
bank's ATM, and the bank examined their video surveillance tapes to find
who caused the mess and found out that it was from a 3 year old girl
whose mother had withdrawn money at the ATM (and they got the mother's
name from the ATMs log).  They sent this mother a cleaning bill of 50 Euros.

Besides the fact that childs below the age of 7 can not be legally
held responsible for their actions in Germany--and their parents
(or whoever was in charge of supervision) can only be held responsible
in case of gross negligence, it was a violation of german privacy laws
for the bank to examine the video and ATM logs to determine the
mother's name.  And although the bank back-pedaled the day _after_
this story made the news, their privacy violation resulted in a formal
investigation by the public authorities against the bank.



-Martin
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