Re: GDPR compliance best practices?

Hi,

Unfortunatly this important topic of GDPR compliance has not seen much interest.

After asking github about how they would cope with the issue of erasing the author field, they changed their privacy policy, which now clarifies that this won't be done.

My guess is that this would ultimately rely on "overriding legitimate grounds for the processing" (Art. 17 (1) point (a) GDPR) which is one of the most fragile legitimizations avaiblable in the GDPR.

The GDPR emphasizes the importance of using state of the art technology, including anonymization, in as much as possible to ensure privacy.

At https://public-inbox.org/git/CA+dhYEViN4-boZLN+5QJyE7RtX+q6a92p0C2O6TA53==BZfTrQ@mail.gmail.com/T/ there is already some discussion about transitioning to a different hashing algorithm to get more in line with state of the art in hashing. (My clear favourite would be SHA-3.)

In course of this, anonymization could also be added. My idea would be as follows:

Do not hash anything directly to obtain the commit ID. Instead, hash a list of hashes of [$random_number, $information] pairs. $information could be an author id, a commit date, a comment, or anything else. Then store the commit id, the list of hashes, and the list of pairs to form the commit.

If someone requests erasure, simply empty the corresponding pair in the list. All that would be left would be the hash of the pair, which is completely anonymous (not more useful than a random number) and thus not covered by the GDPR. The history could still be completely verified, and when displaying the log, the erased entry could be displayed as "<<ERASED>>".

What do you think about this?

Best wishes Peter