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Anything else to consider when hosting a Lemmy instance in the EU? (lemmy.one)

submitted 1 year ago by [email protected] to c/selfhosted

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I'd be really keen to host a lemmy instance but just wondering with GDPR and everything, if there is anything else to consider outside of the technical setup and provisioning of hardware?

Lemmy is storing users data so is there any requirement to do anything GDPR wise?

Hope this is the right place for this - But seen a lot of posts interested in hosting their own lemmy instance, and this is an extension of that

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[–] [email protected] 5 points 1 year ago* (last edited 1 year ago) (5 children)

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 an internal identifier required for operation only. IANAL but I don't think votes can be considered personal data under the GDPR.

[–] [email protected] 1 points 1 year ago (4 children)

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.

[–] [email protected] 1 points 1 year ago (2 children)

I think as @[email protected] 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

[–] danieljackson 4 points 1 year ago (1 children)

The link I provided says that pseudonymous data can be used to hide personalized data.

If you are a DPO, you can see the appeal and benefits of pseudonymization. It makes data identifiable if needed, but inaccessible to unauthorized users and allows data processors and data controllers to lower the risk of a potential data breach and safeguard personal data.

GDPR requires you to take all appropriate technical and organizational measures to protect personal data, and pseudonymization can be an appropriate method of choice if you want to keep the data utility.

The owner of lemmy.one can use [email protected] 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

To delete personally identifiable data
Unlink the personally identifiable data from the pseudonymized data on your local instance.

Disclaimer, IANAL, YMMV, yaddy, yadda,...

[–] [email protected] 1 points 1 year ago

Understood, missed that subtelty. The fact emails aren't actually shared makes it very GDPR "friendly"

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