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this post was submitted on 01 Jul 2023
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Under GDPR, any piece of potentially identifying information is considered personal data. I had GDPR training at work. Under the GDPR it's not even possible to count unique visitors to your website because you'd have to keep track of some identifier even if just IP address and User-Agent, even if it's entirely client side. You still have to get consent for this.
Even just community subscriptions is plenty of data to make a rather comprehensive profile of the user's interests, and if you throw in votes it quickly becomes scary.
This is everything you upvoted:
Obviously IP addresses are personal data, but those are not shared to other instances.
You could probably argue that the federated ID is personal data, but I am not sure as it might also count as only an internal identifier required for operation. IANAL but I don't think votes can be considered personal data under the GDPR.
Question boils down to where is the boundary. Does an alias of your choosing, which uniquely identifies you across the fediverse personally identifiable? I think we all would say yes. Does then actions linked to that alias constitutes as personally identifiable? Well, in absence of the correlation of the ID, it is still technically possible to map out who this user is and what their interests and preferences are, so maybe yes? That’s a hard grey area to determine IMO.
I think as @danieljackson@lemmy.world commented slightly higher up, this might be considered pseudonymised data? The link he provided suggested it was considered personally indentifying information - I'm (as per my question) definitely no expert in this though
The link I provided says that pseudonymous data can be used to hide personalized data.
The owner of lemmy.one can use tk338@lemmy.one to map it to an IP and/or email address. This becomes now personally identifiable data. But other instance owners can't map it to any personalized data, so it is basically "anonymized data" for them.
You just have to provide a way to either
Disclaimer, IANAL, YMMV, yaddy, yadda,...
Understood, missed that subtelty. The fact emails aren't actually shared makes it very GDPR "friendly"