General Data Protection Regulation is coming
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Holzgraefe, Susanne (miracee)
The European General Data Protection Regulation will apply in May 2018. What does this mean for your software? What do you need to consider? Which information do you need to publish?
 We are talking about the general data protection regulation. It will come in May 2018. It's a European regulation. There are only a few things Germany could make better, harder. Like kids aged with European laws, there's something about kids with 16 are allowed to decide. By their own, Germany could make it for 13. There is a new German data protection law, but it's not valid yet. It's a question if it ever will get valid because it's against the European law. What I will tell here is mostly what's relevant for software developers. What needs to be changed or to considered. My slides are only valid with my talk. They have no spent-along meaning. That's very important. They belong to the talk. I made my slides Bealing Grill because there are so much law words that even I didn't know in English before. I said I will do the slides mostly in German and English. When you don't know the English word, you may know the German word. By doing this, I figured out a bug in the translation. I posted it to the European Union and they said, wow, that's a translation bug. You are right. It was really funny. My name is Susanne Holzgräfe. Some of you know me from PostgreSQL and my SQL, MariaDB already, but I have a second hobby or a second business. I do it also. It's also my business is data protection. I'm a data officer, data protection, data protection consultant and trainer. I educate data protection officers. I'm a member of the Deutsche Vereinigung für Datenschutz. That's the oldest group we have in Germany. That's about me. The first question I have, what do you think means data protection? I know that you know it. Don't ask me. Data protection, the reason for the loss in Maine is to protect your data from the government. The government don't get your data and by using your data having power over you. And data protection, the second reason why we have so strong data protection laws is to protect you from advertising. That's the two biggest reasons. I have a second question where you can think, what means private for you? It's a very personal question, what means private? Because there are people, they need more private space than others. There are couples who say it's totally fine when my husband or my wife reads my emails and chats with my friends. And there are others who say, oh no, that's a no-go, my husband or my wife should not read it. I won't read it from my partner too. It's just an example. So private is very individual, but there are rules what the government or the laws call private. But that's the example I just gave, it's pretty private. So data protection is self-determination instead of alien determination. I looked for translation for the word fremdbestemung. I found of course the official Latin word, but when I would tell you, nobody knows what it is. And there were, yeah, alien determination was the most close. And I thought it's funny to have this word alien in it. It's what Google translated on it. So yeah, there is no real translation for the German word mündigkeit. Mündigkeit means the ability to care for your own, that you are responsible for what you are doing by your own. You are able to care for your own. The government don't need to care for you. Yeah, data protection means privacy protection. Data protection means anonymity. Data protection means freedom. And data protection means protection against government and advertising. I already told you. There are three very important reasons for data protection. Sorry, four, three reasons for them. It's lawfulness, so data protection should be lawfulness, fairness and transparency. That's the background behind data protection, lawfulness, fairness and transparency. And when you read the German data protection rules from the European Union, you will find a translation in it for fairness that's incorrect. So fairness means what we call in German fairness. True. So more, another reason for data protection for the law is the purpose limitation. So you are only allowed to store data for one purpose or for the purpose. So you are not allowed to take my data that you got from me for purpose A, to use them for purpose B without my agreement. So purpose limitation. Then another is mandatory. You are only allowed to ask me for personal data if it's really mandatory to make a business with me. And you are only allowed to store this data when it's mandatory for the business. We have with each other without my allowance. For all other, when you want to store any other single information about me, you need my allowance. So when you are in an online shop and I want to buy new shoes from you, you are allowed, of course, to ask where to deliver. That's okay. And of course you are allowed to ask about my shoe size because you need it to send me the right shoes. But you are not allowed to ask me about my hair color or whatever else. If I don't need an invoice, you are not even allowed to ask an invoice address because you don't need it. But you are allowed to store it as long as the package is delivered as long as the business isn't finished without my allowance. So when you want to store it more longer or when you want to send me advertising, you need to ask me. And when you ask me and I say yes, I always have the possibility to withdraw this and you immediately have to react. So when I say stop sending me advertising, you immediately should stop sending me advertising. That's it. So it's end of data minimization. So you should not store too much data. So we have a deleting duty in the European law and we have a really deleting duty. In the actual German law, you have a deleting duty, but it's okay to lock the information when it's too difficult to delete them. That's not anymore in the European law. In the European law, you need to delete them. The European law says when your tool isn't able to delete it, then it's a wrong tool. Then you should use a new tool. You should redesign your tools. Deleting is important. There is a deleting duty. There's one locking justice allowed when there is a law that allows you to store the data more longer, for example, for banking secrets or whatever else. But then you need to anonymize, to pseudonymize the data. But usually you have to delete them after the purpose is fulfilled. Another thing is accuracy. So it's up to you to make sure that the data are correct, valid. If the data aren't valid, or if you aren't sure that they aren't valid, you have to delete them. Storage limitation, that's also a deletion. So storage limitation is you have to delete the data after the purpose is fulfilled, or when it was a storage for which you have my allowance. When I restore the allowance, you immediately have to really delete the information about me. Then we have integrity and confidential. So you make sure that my data, that all your employees, and all the companies where you, all your sub-companies, that you have who be confidential with my... act confidential with my data. So it's up to you when you hire a sub-company to make sure that my data are confidential. They really take a confidential care. And the last is accountability. So you have to tell the users what you are doing with their data. Precisely. So... If we had this slide, I don't know. So there are special... All information about a single person have the same priority, or the same confidential. There are kinds of information, categories of information, which are high confidential. That are information about racial and ethical origin, political opinion, religious or philosophical beliefs, trade or trade union membership, and the processing of genetic data, biometric data, data concerning health, or data concerning a natural person, is sex life for sexual orientation, and data for when you were in prison. That are special categories of data. I won't tell more about this in this talk, because it's a very difficult area. You have to consider way more of stuff. But you can ask me a lot about it, because I'm a specialist for this kind of data. So you have a deleting duty, I already said it. You immediately, after fulfillment of purpose, you need to delete the information after opposition period. So that means a fulfillment of purpose means after opposition period. Looking instead of deleting is not allowed anymore. We thinking towards a decision I already told you, and every information that belongs to a group of minimum of 3 persons, because that's when it's not anonymity anymore, has to have an expire date. So when you say an expire date, after that you have to delete it. New is pseudonymization, and that's awful. For pseudonymization, you need minimum 3 physical separate servers. You need one for the origin data, one for the key, and one for the pseudonymic data set. And you have to be sure that when you pseudonymize your data set, that with all the information in your data set, you can't find a group of 3 people, less than 3 people. So that means when you just have the pseudonymic data set, nobody should be able to figure out to whom belong this data set. And 3 people always is the minimum you need for anonymization, for that's not clear anymore to whom they belong. There's a minimum of 3 people for that. So it has to be impossible to identify a person by data set content. So, pseudonymization, you always need, generally need for sensible data. That was this group of health and sexual life and political opinion and so on. And after the purpose fulfilled, when you have a law that says you need to store the data further on the next 3, 6, 10 years, you need to pseudonymize them. Yeah, for storage studio. That's awful because it's lots of work if you didn't start it yet. The penalty if you, for not following the European data protection rules, is 20 or 40 million dollars you, or if that's not enough for your company, 2 or 4% of your worldwide, I don't know the English word, what? Revenue. Revenue, yeah, revenue from the last year. So, the European Union wants that it really hard when you finally don't, yeah, you have a question. Yeah, when you want to pseudonymize, that means you have a key with which you can get the data. You have a key like, yeah, encryption key, yeah, encryption key, yeah. To get it back, so that's the difference between anonymization and pseudonymization. You have to make sure that nobody will ever get their origins back, and by pseudonymization you can get it back. You don't really need the key because you just assign the unique way you should use the data by unique way you're consistent. Yeah, but you need to be the big, so not the, the administrators have to be three different persons. So, the administrator of the pseudonymic server should not be allowed to figure out what the origin data. So, I just, that's typical at the moment, how else do it? They have three servers. They have this encryption key on one server. They have the origin and data because the doctor needs to still work with it, and they have pseudonymization data for research, for example. And in any way, you have to make sure, and you also have to make sure that the service people for the database aren't the same person for your origin data and for your pseudonymize. Yeah, you'll be just for storage reasons, you just need to, you need the key and the pseudonymization, so that you get back here. But when you need the origin data for, for this health reason, for example, because there you always need to pseudonymize. Yeah, there is another new thing. Most web, web online shops and online have it already, but for other, it might be a lot of more work. The European law says the controller should provide remote access to a secure system which would provide the data subject with direct access to his or her own, or her personal data. That means I always should be able to watch my own data. It's just looking, it's just reading. So I know lots of companies already provide it and you are also able to change your own data. I could change my last name after I married. Lots of companies I could change my last name by my own or when you move, you could change your own address and so on and so on. But there are lots of companies where you can't see it. Also Facebook and Twitter, you are able to change your own interests. You always can say, no, that's not my interest. But you need to do it very often because they always find, think you have very odd interests. You should. And it's in the pre-definition of, so it's in the pre-definition it's 6.63, so you should. So this is not something that is being legal directive from you, so how does it define your personal data? All what belongs to a single, all information is about a single person. So information that you can, that can be, which with, you can describe a single person. So where you can match, for example, it's when your shoe size, when I have Sergei and your last name, I don't want you to tell it now. Sergei has black t-shirt, he loves programming, he always wears green shoes or whatever else, all personal information about you. But if you control shoe size, it might be information, or it might be information for whatever company. Yeah, yeah, but when you store them with your name, it's your shoe size. So it's not, I'm a shoe vendor and I have shoes in 38, 39, 40 and so on. So that's of course no personal information, but when I store Sergei, he has shoe size 39, for example, then it's a personal information. What's the status of data which is not sensitive about you, but which one combined can reveal some sensitive information? So are you allowed to infer from the data making this person has sexual orientation or... sexual orientation, there is a classical, they discuss it at the moment that we need a special... so we expect that the judge will decide that way. The data protection law always just rules for living, don't rule for dead people. But when we have genetic data, it can be that the person is dead, but it's a nilness, he has had a nilness where it's very... where the chances his son also will get this illness. So when he's dead, so the whole family is hit. So that's a sensible data too. And there's other information about shoe size, favorite color, the kind of thing you wear. And the company can maybe highly confidently identify you as belonging to a particular group. You are not allowed to store that, even not with allowance. But you don't keep innocent information that you are not here that you can identify a person. Like I contract, I don't know, purchases in a supermarket by Napa on a bonus card. It's not a touch-dating particular person, there's not a person on the provider. Then a mobile phone provider can track location based on certain topics. Also it's not a touch-dating particular person, it's a phone. Combine those, combine some other pieces and very minimally identify the person. Yeah, exactly. But all those pieces themselves are not sensitive to that. Yes, exactly. And when you combine it, then you have personal information. And on the sensible information, they are only allowed to store and to ask for from non-profit organizations. Where the main business is around that you are asking for. So health data only from health information and sexual information from sexual. They don't even have to store it because they can always incur it. They don't have to store it because they can incur it. They can deduce it, but they don't have to store it. You are not allowed to ask for it. They can deduce it from the data, but we don't have to store the sensitive information. What happens in such a way? We can discuss it later because... Transparency. Transparency means you have to be concise, transparent. The transparency has to be concise, transparent, intelligible, easily accessible from using clear and plain language. That's very important. All the information you have to hand out to your users, to the people from whom you have personal information, they have to be written in clear and plain language. When you store information about children, it's even more than plain. In German it means light. I don't know the English word for lightesprache. So usually it's enough to have einfache Sprache, when you have children you have to write it in leichte Sprache. To that, there is a different kind of transparency. The question I wanted to ask is, whether the data access is required to be in some kind of machine-readable form? So it's only in the part where... This information needs to be in plain form, we will see it on the next slide. You need to... The information needs in plain text, or even spoken, or even with pictograms. So that every person from whom you collect information will understand it. Children have to understand it. Providing in writing. Yeah, you have it. Providing in writing. When requested additional overly, for example when you have customers who only understand overly, when they request for overly, you have to read it to them. The slide is not about data, but about the information of the person, transparency. Permissions for you to store information that I gave. No, not the permission you give, always. Also when you don't need a permission from me, you have to inform the person from whom you store the data, what you are doing with it, and so on and so on. We will see what you all have to... What information you have to give them. And that has to be in plain language. Simple language is the word for the other. So, yeah, that's what I said. You have to inform them, and it's a lot what you need to inform them. So always, before or while, you are asking for the data. My idea is when you are asking for information on the pages, or via internet, you could do it like... We do it today with the business rules between you and the customer. Just make a page where all is given, and then make a checkbox where the user needs to check, I've read it, before he can go further on. So, it's information duty. What needs to be in it, you need to point out who... I can contact who is responsible for the data, who is your data protection officer. You need to point out the data protection officer contact address. At the moment, it's hard. Every company needs, or most companies, the data protection officer, lots of companies, and the data protection officer... You always can... I'm allowed to talk with the data protection officer without the company knowing about it, but it's mostly difficult to find out who is the data protection officer without contacting the company. So, today you have to go to the government and the government will ask the company, and then you get the data protection officer and contact data. It's difficult. And so, the European Union says that these contact data needs to be given public. You have to make it public, but all you have to tell every person from whom you store the data, the information from whom you will get the data, who is your data protection officer and how you can contact him or her. And you need to make sure, make clear who is responsible for the data, so who will pay for it when the data get lost. So, that's easy. Most times, there are organizations where it's not clear who is responsible, but most often it's clear. You need to point out the purpose why you need the data. And when there is a legal basis, you need to point out the legal basis, if there isn't a legal basis. You either have a real good reason like, I can't deliver the package when you don't tell me where to deliver. That's a pretty clear and logical reason. And otherwise, you need the agreement. And also for other purposes. So, you can't just say, I want your data for sending you an invoice and for advertising. So, that's not okay. So, you can see for invoice and then you can point out the invoice legal laws, but the text law paragraphs, but for advertising, there is no legal law. So, you would need an agreement. Then, where the processing is based on point of art, where the process is based on F. You need to point out who will get your data, who will work with it, for example, marketing. But it's not good having marketing without agreement. But also when you have others who will work with it. You need to point out to whom you transfer the data. And if you transfer them to a third party company, to a non-European union country, and international organizations who are similar to non-European countries. Non-European means non-European union, Switzerland, nor Norway. So, Norway and Switzerland, the law is okay. But that's not all. That's all information you already need to provide now. Because we have this already in the German law, that you need to provide this. If you didn't do it at the moment, you should do it because it's way more penalty if you don't have it. And that's something, if you don't have this information, it's the 40 million, no, 20 million, it's a higher one. 40 million or 4%, or 20 million and 4%, something like that. So, 20 and 4 is just, yeah. But you need to inform the people more. There are much more you need to inform the person, yeah, for when the data are obtained. Oh, wait. The period, how long you will store the data? It's also something you already needed to have. But the existence of the right to request. So, when you have an agreement, then you need to tell the person that they have the right to request it immediately, and you will immediately stop whatever you did with the data and delete the information. And you need to inform the person in plain language. So, yeah. You need to point out all this law that he has, that he can complain, also that he can complain at the government, or at the government office who is controlling this. You need to inform him. And, yeah. And so you have to do lots of law stuff. All this rights the person has, you need to inform the person about their rights. That's very important. I not yet saw it, but maybe there will be some people who provide forms and examples how you can write this legal stuff. I not yet saw it somewhere, but... I think that's about the credit and the percentage of things they have. Ah, yes. Yeah, yeah, that's... From the things they've watched and the age, and if they make the credit... That's also, when you do profiling and so on, then you need to inform them. I just wanted to stop because it's a lot of information. So it's just you need to read it anyway what you need to inform them. But it's a lot. And when you don't inform the user or the person, it's very expensive. Yeah, and you also need them if you want to use the data to different profiles, of course. As I said, the solution is easy. When you have online business, just mark, I read it, and good. The most effort, I think, is writing all the stuff. Ah... So, the summary, what's the most important you need to consider? It's the deleting duty. It's the remote access. It's the pseudonymization. And this is information duty. That's the most important point you need to consider. Ah... This information duty, half of them you already have from German law at the moment when you did it, when you didn't did it. So now you really should do it. Pseudonymization, I guess, is most effort for all. And remote access, yeah, most have it anyway. Usually when I'm a customer of a company who provides something online, I can change my data. I cannot even read my data. I also can change it. The deleting duty, because we have in Germany, at the moment, you should delete, but when you can't delete, you can lock, and most companies just block. There are lots of companies where even is the... You can't remember that. They think it's very difficult to delete even when it's easy. So what's difficult to delete is a feeling, yes? How does this... I was reading a draw. You go where, for example, I did this, so you have like... I'm not sure you're logging. Logging with G. Yes, so what's that I did this to... You can see once a bubble wall is going in, logging out in my... It's long, it's simple, whatever. What happens to that kind of... You are not allowed to... You are generally not allowed to control your employees. For example, or... If I have to cost-review by something from my company, I might be in a get request, so I'm giving this into my log data analyzer and it's not for something I can never delete out. So does it apply to logging to security? No, you would not... There is no law for this, so you are not allowed, without my allowance, to store that anyway, to store that in any kind. Well, I might have to because I'm in a banking regulation. No, no, sorry. When I said there is no law, of course, there are bank secret laws, there are some laws where they have... Like banks have own secret laws, churches often have it, health companies, yes? If you are... You have to service your employees, so you are not allowed to collect dogfights, but you are not allowed to analyze them for statistical purposes also. Use dogfights to check on your employees. You are not allowed to use dogfights to keep up. Yes, but if the customer requires information, the owner requires a commission of all data and storing it out. Yes. So when I have the data in my log aggregation, it's like, well, it's just not possible to... Yeah, exactly. That would change the knowledge to have statistical purposes, from the company of the state, to your data, if you are able to go back to the person you just know they are from, you can have it anonymized, without any other people, without any user names, without any possible error. Exactly. You can use it as a statistic, but not if you are able to go back to the person you just know that, not about the stock data, not about the data. Statistics should be... It's a well-worked case. Sorry, but not now. Yeah. So, the question is... Now, in any case, statistical data needs to be minimums for an individual. So, the question is, how do you... How do you... How do you... How do you... How do you... How do you... How do you... How do you... In any case, statistical data needs to be minimums for anonymized. You are not allowed that you can... So, the same for health data, for example, you always, when you have statistical data, they have to be anonymized. And in that case, they have to be anonymized. Because you have no law, no right to do it. There is no law that... Besides banking or so, but in standard use, you don't have a law for it. And then you are not allowed to do it. It's very simple. And when they... So, your customer also can say, okay, you start my IP address, you didn't ask me for it, and then you have to pay the penalty. He can go to the officer and say, hey, here, look. And what's also allowed is that not only the person himself can go to the officer. That's at the moment. Or, no, I don't know if it's still at the moment. I don't know if that's the German law. So, there can be organizations going against you, like Verbraucherschutz. They are allowed to complain about you at the officer, and then the officer also will get your penalty. So, at the moment, as the old law was, that only the person who... the person himself and the data protection officer were allowed to complain at the officer. But there is a new German law that says that also organizations like Verbraucherschutz can complain. And, yeah. So, what is the deletion duty with backups? So, if you have a backup or database which you keep around 15 a month, but then someone says, I want... right, the deletion duty comes into play because... So, a month is not a problem anyway because three months is minimum for what the English word and post-frist. I forgot it. Redention. Yeah. And so, a month is not a... And usually, at the moment, the officers say, the deletion year is okay. So, that's... But that's not in the law. That's how our judges decided and they said when you delete and remove all by end of your... your business year, it's okay. But the three months you have anyway, so... So, it's not immediate... Yeah, of course. Of course. The law says immediately, means after the... I still... Potential time is over. So, you have the three months and judges are a little bit more... Okay. Latest at the end of your business year. So, yeah. What about archive systems which are particularly protected against deletion because there is no laws... For instance, banks must use archive systems which are particularly... There is a law for it, also for health services. Okay. So, you have... Did you sign a mis-ation? Yes. Anyway, for... Yeah, you need to... So, when you have archiving law without deletion... Anyway, when you have a storage or archiving law, then you need to pseudonymonize. The customer kind of asked to... No, because there is the law that you need to archive it. And for health, of course, you need to pseudonymonize already before, but on other data, you need to pseudonymonize when you start archiving. Hmm? The question was already asked, but I would like to bring it up here just for... Because I didn't quite get it, there will be a reliable way to find out is this big personal information yes or no without it being kind of debatable. I guess when we want to... You know, for laws, it has to be kind of... So, it's definition of what is personal data. No. It's... Yeah, it's pretty clear what is personal data. The question is what is personal data? Personal data are all data that belongs to you. So, or, Hannah, do you have... Completely....kind of data which describes you or is there any truth identifying you as one person... Yeah....in a group of... Any info......for people that only one has glasses, then the information you are the person who is wearing glasses is the thing of information which identifies you. Yeah. So, to make sure that any kind of information you have is not able to identify another person and say no data... to identify any person that's not a personal data. So... And now say this... The problem is that three weeks of day... No, no. Now, you have... That's exactly... So......a lot of people just call my question because it's my question. Let me first repeat for the camera. So, any information with which a single person can be identified... The example was when you have a group of people and just one is wearing glasses, then it doesn't matter how big the group is. So, the one of having wearing glasses always can be identified. And for... And... It needs to be minimum for people or three and more. It's my information that you can't identify... With same information, where judges say it's... You can't identify a single person anymore. So, when you have a group of four people wearing glasses, then it's okay, but when you just have a group of 100 people wearing glasses, then the person with glasses is clearly identified. Yeah, your second question. Thank you. My question is actually as of before, this is, I guess, with this kind of definition, as it's called out, we could infer things. So, with the advancement in AI and machine learning, we see sometimes the serenity effect. So, we thought there's no link there, but then at some point, the link is... Yeah. So, at that point, that becomes sense. Exactly. So, if you're in a company and you have to invest it in something that faces all these information, you're not facing the... So, for companies, it could be kind of like, what am I allowed to store at all? I'm facing every kind of question. So, I guess that's kind of the point that I was putting forward. You're only allowed to store when you really need the information for the business. You make a simple example. You have a person in a true wearable, a true wearable, a white one, a white white one, the person with glasses, the person with glasses is unfortunately identifiable. So, you don't need to ask people, or you don't need to delete it, you can store it as much as you want. You can store information, the person with glasses, it's also not identifiable. You don't need to put it in a white one. No, because you don't... You don't combine it together, just store it separately. Yeah, when you don't have any other further information, the person's wear a green t-shirt, that's not personal information, but when you have the names of the persons, green t-shirt, green t-shirt, green t-shirt, then of course you know who wears green t-shirts in your data set. I don't need a name. I can try to call the person's activity under the tag who wears glasses and wears black. So, I don't really need a name if I want to identify the person. I mean that I identify persons by two different characteristics. Each one of them is not... Yeah, but you need a second when you just have... I'm going to put the other one in the phone, please. Yeah. When there's no other information just persons with glasses and without glasses, you don't know who... And when you have 3,000 customers, you don't know who wears glasses. Oh, 5 minutes, okay. Yeah. You said you used to request the definition of state as a regulator as well, or could it be anything like a phone call or email? Anything? Email is difficult because... Email always is difficult because email always you have a combination of two persons. Because it's a chat between two persons. So, both persons have rights. I'm not sure if I understand. Let's say I have a... So, I want to request that the shop is debuting my name. So, the shop has its email address somewhere on the website. Yeah. Is that allowed? Yes, of course. And they need to do it. They don't need to delete data where they are who are right that they have to store them. And what was that? Pretension. Yeah. Pretension or... Yeah. Where you keep the information. No. You just can... No, there must be an easy way for you as person to ask for it. So, they have to accept it in written form anyway. No, it doesn't matter if email or not. So, no, not anyway. They need, of course, they need to make sure that you are the person to whom the data belongs. So, that is something to identify you as the data owner. But, no, it has to be a very easy form and it has to given in this information you need to give the person anyway. So, yeah. Yes? I've got two questions. First of all, what happens with this data in cloud like Amazon that can be moved without your consent or notice from area to area? For example, it can be moved from Frankfurt to some other region. So, what happens with data in cloud like Amazon? Like Amazon is an international organization, it's a party. It's even worse. Yeah, yeah. In my case, I'm buying things in Germany, in the US and in India. So, in India, it's mandatory for the Indian organization to comply with this or they don't... No. Imagine the... That's exactly the European law just for you. Yeah, but I mean... That's why... Is the US have to comply with that? Is the UK going to comply with that when once the Brexit is done? Or... We don't know. We don't know. Yeah. How do you get that information outside? Okay, Great Britain has stated that they will comply to... Yeah, and......the market. But when you run a business, it's your part to ensure that your company's purpose and office. Exactly. If you come from church or meet Microsoft Office, that allows... Whenever you're here, he says, anyone based in the EU or anyone pending a target in the personal data will be you based in the EU. Yes, exactly. EU? No, no, no, there's no... That's why... You're not just in the EU based in the EU. So, the law just belongs... It's for you. That's why you need to point out that you will give you the data out of the European Union. And there are no way in Switzerland belongs to it too. That's a special... And, yeah, as he said, UK too. So, I want to wait what UK still is you. But there was a question and there was a question. And we have five seconds, I think we can... We have talked about the European directive, but which countries do you think have actually made it wrong? What? This one was the other one that the European Union directed, but they are not automatic for every country. So, which countries... All European Union countries. Is it or an occurrence? Yeah. And you had a question. Someone who is not a EU citizen. Yeah. Always laws protect them if the data is stored in an EU... Yes. The law also, of course, would for... Protect not European citizens as long as the data and the businesses is in the EU and you are living in the EU. So, it protects you as every European people. Yeah. We have to stop. 58 seconds after... Okay. Thank you. Thank you.
 We are talking about the general data protection regulation.  It will come in May 2018.  It's a European regulation.  There are only a few things Germany could make better, harder.  Like kids aged with European laws, there's something about kids with 16 are allowed to decide.  By their own, Germany could make it for 13.  There is a new German data protection law, but it's not valid yet.  It's a question if it ever will get valid because it's against the European law.  What I will tell here is mostly what's relevant for software developers.  What needs to be changed or to considered.  My slides are only valid with my talk.  They have no spent-along meaning.  That's very important.  They belong to the talk.  I made my slides Bealing Grill because there are so much law words that even I didn't know in English before.  I said I will do the slides mostly in German and English.  When you don't know the English word, you may know the German word.  By doing this, I figured out a bug in the translation.  I posted it to the European Union and they said,  wow, that's a translation bug.  You are right.  It was really funny.  My name is Susanne Holzgräfe.  Some of you know me from PostgreSQL and my SQL, MariaDB already,  but I have a second hobby or a second business.  I do it also.  It's also my business is data protection.  I'm a data officer, data protection, data protection consultant and trainer.  I educate data protection officers.  I'm a member of the Deutsche Vereinigung für Datenschutz.  That's the oldest group we have in Germany.  That's about me.  The first question I have, what do you think means data protection?  I know that you know it.  Don't ask me.  Data protection, the reason for the loss in Maine is to protect your data from the government.  The government don't get your data and by using your data having power over you.  And data protection, the second reason why we have so strong data protection laws is to protect you from advertising.  That's the two biggest reasons.  I have a second question where you can think,  what means private for you?  It's a very personal question, what means private?  Because there are people, they need more private space than others.  There are couples who say it's totally fine when my husband or my wife reads my emails and chats with my friends.  And there are others who say, oh no, that's a no-go, my husband or my wife should not read it.  I won't read it from my partner too.  It's just an example.  So private is very individual, but there are rules what the government or the laws call private.  But that's the example I just gave, it's pretty private.  So data protection is self-determination instead of alien determination.  I looked for translation for the word fremdbestemung.  I found of course the official Latin word, but when I would tell you, nobody knows what it is.  And there were, yeah, alien determination was the most close.  And I thought it's funny to have this word alien in it.  It's what Google translated on it.  So yeah, there is no real translation for the German word mündigkeit.  Mündigkeit means the ability to care for your own, that you are responsible for what you are doing by your own.  You are able to care for your own.  The government don't need to care for you.  Yeah, data protection means privacy protection.  Data protection means anonymity.  Data protection means freedom.  And data protection means protection against government and advertising.  I already told you.  There are three very important reasons for data protection.  Sorry, four, three reasons for them.  It's lawfulness, so data protection should be lawfulness, fairness and transparency.  That's the background behind data protection, lawfulness, fairness and transparency.  And when you read the German data protection rules from the European Union,  you will find a translation in it for fairness that's incorrect.  So fairness means what we call in German fairness.  True.  So more, another reason for data protection for the law is the purpose limitation.  So you are only allowed to store data for one purpose or for the purpose.  So you are not allowed to take my data that you got from me for purpose A,  to use them for purpose B without my agreement.  So purpose limitation.  Then another is mandatory.  You are only allowed to ask me for personal data  if it's really mandatory to make a business with me.  And you are only allowed to store this data when it's mandatory for the business.  We have with each other without my allowance.  For all other, when you want to store any other single information about me,  you need my allowance.  So when you are in an online shop and I want to buy new shoes from you,  you are allowed, of course, to ask where to deliver.  That's okay.  And of course you are allowed to ask about my shoe size  because you need it to send me the right shoes.  But you are not allowed to ask me about my hair color or whatever else.  If I don't need an invoice, you are not even allowed to ask an invoice address  because you don't need it.  But you are allowed to store it as long as the package is delivered  as long as the business isn't finished without my allowance.  So when you want to store it more longer or when you want to send me advertising,  you need to ask me.  And when you ask me and I say yes,  I always have the possibility to withdraw this  and you immediately have to react.  So when I say stop sending me advertising,  you immediately should stop sending me advertising.  That's it.  So it's end of data minimization.  So you should not store too much data.  So we have a deleting duty in the European law  and we have a really deleting duty.  In the actual German law, you have a deleting duty,  but it's okay to lock the information when it's too difficult to delete them.  That's not anymore in the European law.  In the European law, you need to delete them.  The European law says when your tool isn't able to delete it,  then it's a wrong tool.  Then you should use a new tool.  You should redesign your tools.  Deleting is important.  There is a deleting duty.  There's one locking justice allowed when there is a law  that allows you to store the data more longer,  for example, for banking secrets or whatever else.  But then you need to anonymize, to pseudonymize the data.  But usually you have to delete them after the purpose is fulfilled.  Another thing is accuracy.  So it's up to you to make sure that the data are correct, valid.  If the data aren't valid, or if you aren't sure that they aren't valid,  you have to delete them.  Storage limitation, that's also a deletion.  So storage limitation is you have to delete the data after the purpose is fulfilled,  or when it was a storage for which you have my allowance.  When I restore the allowance, you immediately have to really delete the information about me.  Then we have integrity and confidential.  So you make sure that my data, that all your employees,  and all the companies where you, all your sub-companies,  that you have who be confidential with my...  act confidential with my data.  So it's up to you when you hire a sub-company to make sure that my data are confidential.  They really take a confidential care.  And the last is accountability.  So you have to tell the users what you are doing with their data.  Precisely.  So...  If we had this slide, I don't know.  So there are special...  All information about a single person have the same priority,  or the same confidential.  There are kinds of information, categories of information,  which are high confidential.  That are information about racial and ethical origin,  political opinion, religious or philosophical beliefs,  trade or trade union membership,  and the processing of genetic data,  biometric data, data concerning health,  or data concerning a natural person,  is sex life for sexual orientation,  and data for when you were in prison.  That are special categories of data.  I won't tell more about this in this talk,  because it's a very difficult area.  You have to consider way more of stuff.  But you can ask me a lot about it,  because I'm a specialist for this kind of data.  So you have a deleting duty, I already said it.  You immediately, after fulfillment of purpose,  you need to delete the information after opposition period.  So that means a fulfillment of purpose means after opposition period.  Looking instead of deleting is not allowed anymore.  We thinking towards a decision I already told you,  and every information that belongs to a group of minimum of 3 persons,  because that's when it's not anonymity anymore,  has to have an expire date.  So when you say an expire date, after that you have to delete it.  New is pseudonymization, and that's awful.  For pseudonymization, you need minimum 3 physical separate servers.  You need one for the origin data,  one for the key, and one for the pseudonymic data set.  And you have to be sure that when you pseudonymize your data set,  that with all the information in your data set,  you can't find a group of 3 people, less than 3 people.  So that means when you just have the pseudonymic data set,  nobody should be able to figure out to whom belong this data set.  And 3 people always is the minimum you need for anonymization,  for that's not clear anymore to whom they belong.  There's a minimum of 3 people for that.  So it has to be impossible to identify a person by data set content.  So, pseudonymization, you always need, generally need for sensible data.  That was this group of health and sexual life and political opinion and so on.  And after the purpose fulfilled, when you have a law that says  you need to store the data further on the next 3, 6, 10 years,  you need to pseudonymize them.  Yeah, for storage studio.  That's awful because it's lots of work if you didn't start it yet.  The penalty if you, for not following the European data protection rules,  is 20 or 40 million dollars you,  or if that's not enough for your company,  2 or 4% of your worldwide, I don't know the English word, what?  Revenue. Revenue, yeah, revenue from the last year.  So, the European Union wants that it really hard when you finally don't,  yeah, you have a question.  Yeah, when you want to pseudonymize, that means you have a key with which you can get the data.  You have a key like, yeah, encryption key, yeah, encryption key, yeah.  To get it back, so that's the difference between anonymization and pseudonymization.  You have to make sure that nobody will ever get their origins back,  and by pseudonymization you can get it back.  You don't really need the key because you just assign the unique way you should use the data by unique way you're consistent.  Yeah, but you need to be the big, so not the, the administrators have to be three different persons.  So, the administrator of the pseudonymic server should not be allowed to figure out what the origin data.  So, I just, that's typical at the moment, how else do it?  They have three servers. They have this encryption key on one server.  They have the origin and data because the doctor needs to still work with it,  and they have pseudonymization data for research, for example.  And in any way, you have to make sure, and you also have to make sure that the service people for the database  aren't the same person for your origin data and for your pseudonymize.  Yeah, you'll be just for storage reasons, you just need to, you need the key and the pseudonymization, so that you get back here.  But when you need the origin data for, for this health reason, for example, because there you always need to pseudonymize.  Yeah, there is another new thing.  Most web, web online shops and online have it already, but for other, it might be a lot of more work.  The European law says the controller should provide remote access to a secure system which would provide the data subject with direct access to his or her own, or her personal data.  That means I always should be able to watch my own data.  It's just looking, it's just reading.  So I know lots of companies already provide it and you are also able to change your own data.  I could change my last name after I married.  Lots of companies I could change my last name by my own or when you move, you could change your own address and so on and so on.  But there are lots of companies where you can't see it.  Also Facebook and Twitter, you are able to change your own interests.  You always can say, no, that's not my interest.  But you need to do it very often because they always find, think you have very odd interests.  You should.  And it's in the pre-definition of, so it's in the pre-definition it's 6.63, so you should.  So this is not something that is being legal directive from you, so how does it define your personal data?  All what belongs to a single, all information is about a single person.  So information that you can, that can be, which with, you can describe a single person.  So where you can match, for example, it's when your shoe size, when I have Sergei and your last name, I don't want you to tell it now.  Sergei has black t-shirt, he loves programming, he always wears green shoes or whatever else, all personal information about you.  But if you control shoe size, it might be information, or it might be information for whatever company.  Yeah, yeah, but when you store them with your name, it's your shoe size.  So it's not, I'm a shoe vendor and I have shoes in 38, 39, 40 and so on.  So that's of course no personal information, but when I store Sergei, he has shoe size 39, for example, then it's a personal information.  What's the status of data which is not sensitive about you, but which one combined can reveal some sensitive information?  So are you allowed to infer from the data making this person has sexual orientation or...  sexual orientation, there is a classical, they discuss it at the moment that we need a special...  so we expect that the judge will decide that way.  The data protection law always just rules for living, don't rule for dead people.  But when we have genetic data, it can be that the person is dead,  but it's a nilness, he has had a nilness where it's very...  where the chances his son also will get this illness.  So when he's dead, so the whole family is hit.  So that's a sensible data too.  And there's other information about shoe size, favorite color, the kind of thing you wear.  And the company can maybe highly confidently identify you as belonging to a particular group.  You are not allowed to store that, even not with allowance.  But you don't keep innocent information that you are not here that you can identify a person.  Like I contract, I don't know, purchases in a supermarket by Napa on a bonus card.  It's not a touch-dating particular person, there's not a person on the provider.  Then a mobile phone provider can track location based on certain topics.  Also it's not a touch-dating particular person, it's a phone.  Combine those, combine some other pieces and very minimally identify the person.  Yeah, exactly.  But all those pieces themselves are not sensitive to that.  Yes, exactly. And when you combine it, then you have personal information.  And on the sensible information, they are only allowed to store and to ask for from non-profit organizations.  Where the main business is around that you are asking for.  So health data only from health information and sexual information from sexual.  They don't even have to store it because they can always incur it.  They don't have to store it because they can incur it.  They can deduce it, but they don't have to store it.  You are not allowed to ask for it.  They can deduce it from the data, but we don't have to store the sensitive information.  What happens in such a way?  We can discuss it later because...  Transparency.  Transparency means you have to be concise, transparent.  The transparency has to be concise, transparent, intelligible,  easily accessible from using clear and plain language.  That's very important.  All the information you have to hand out to your users,  to the people from whom you have personal information,  they have to be written in clear and plain language.  When you store information about children,  it's even more than plain.  In German it means light.  I don't know the English word for lightesprache.  So usually it's enough to have einfache Sprache,  when you have children you have to write it in leichte Sprache.  To that, there is a different kind of transparency.  The question I wanted to ask is,  whether the data access is required to be in some kind of machine-readable form?  So it's only in the part where...  This information needs to be in plain form, we will see it on the next slide.  You need to...  The information needs in plain text, or even spoken, or even with pictograms.  So that every person from whom you collect information will understand it.  Children have to understand it.  Providing in writing.  Yeah, you have it.  Providing in writing.  When requested additional overly,  for example when you have customers who only understand overly,  when they request for overly, you have to read it to them.  The slide is not about data, but about the information of the person, transparency.  Permissions for you to store information that I gave.  No, not the permission you give, always.  Also when you don't need a permission from me, you have to inform the person  from whom you store the data, what you are doing with it, and so on and so on.  We will see what you all have to...  What information you have to give them.  And that has to be in plain language.  Simple language is the word for the other.  So, yeah, that's what I said.  You have to inform them, and it's a lot what you need to inform them.  So always, before or while, you are asking for the data.  My idea is when you are asking for information on the pages,  or via internet, you could do it like...  We do it today with the business rules between you and the customer.  Just make a page where all is given,  and then make a checkbox where the user needs to check, I've read it,  before he can go further on.  So, it's information duty.  What needs to be in it, you need to point out who...  I can contact who is responsible for the data, who is your data protection officer.  You need to point out the data protection officer contact address.  At the moment, it's hard.  Every company needs, or most companies, the data protection officer,  lots of companies, and the data protection officer...  You always can...  I'm allowed to talk with the data protection officer without the company knowing about it,  but it's mostly difficult to find out who is the data protection officer  without contacting the company.  So, today you have to go to the government and the government will ask the company,  and then you get the data protection officer and contact data.  It's difficult.  And so, the European Union says that these contact data needs to be given public.  You have to make it public,  but all you have to tell every person from whom you store the data,  the information from whom you will get the data,  who is your data protection officer and how you can contact him or her.  And you need to make sure, make clear who is responsible for the data,  so who will pay for it when the data get lost.  So, that's easy.  Most times, there are organizations where it's not clear who is responsible,  but most often it's clear.  You need to point out the purpose why you need the data.  And when there is a legal basis, you need to point out the legal basis,  if there isn't a legal basis.  You either have a real good reason like,  I can't deliver the package when you don't tell me where to deliver.  That's a pretty clear and logical reason.  And otherwise, you need the agreement.  And also for other purposes.  So, you can't just say,  I want your data for sending you an invoice and for advertising.  So, that's not okay.  So, you can see for invoice and then you can point out the invoice legal laws,  but the text law paragraphs,  but for advertising, there is no legal law.  So, you would need an agreement.  Then, where the processing is based on point of art,  where the process is based on F.  You need to point out who will get your data,  who will work with it, for example, marketing.  But it's not good having marketing without agreement.  But also when you have others who will work with it.  You need to point out to whom you transfer the data.  And if you transfer them to a third party company,  to a non-European union country,  and international organizations who are similar to non-European countries.  Non-European means non-European union,  Switzerland, nor Norway.  So, Norway and Switzerland, the law is okay.  But that's not all.  That's all information you already need to provide now.  Because we have this already in the German law,  that you need to provide this.  If you didn't do it at the moment,  you should do it because it's way more penalty if you don't have it.  And that's something, if you don't have this information,  it's the 40 million, no, 20 million, it's a higher one.  40 million or 4%, or 20 million and 4%, something like that.  So, 20 and 4 is just, yeah.  But you need to inform the people more.  There are much more you need to inform the person,  yeah, for when the data are obtained.  Oh, wait.  The period, how long you will store the data?  It's also something you already needed to have.  But the existence of the right to request.  So, when you have an agreement, then you need to tell the person  that they have the right to request it immediately,  and you will immediately stop whatever you did with the data  and delete the information.  And you need to inform the person in plain language.  So, yeah.  You need to point out all this law that he has,  that he can complain, also that he can complain at the government,  or at the government office who is controlling this.  You need to inform him.  And, yeah.  And so you have to do lots of law stuff.  All this rights the person has,  you need to inform the person about their rights.  That's very important.  I not yet saw it, but maybe there will be some people  who provide forms and examples how you can write this legal stuff.  I not yet saw it somewhere, but...  I think that's about the credit and the percentage of things they have.  Ah, yes.  Yeah, yeah, that's...  From the things they've watched and the age,  and if they make the credit...  That's also, when you do profiling and so on,  then you need to inform them.  I just wanted to stop because it's a lot of information.  So it's just you need to read it anyway what you need to inform them.  But it's a lot.  And when you don't inform the user or the person,  it's very expensive.  Yeah, and you also need them if you want to use the data  to different profiles, of course.  As I said, the solution is easy.  When you have online business, just mark, I read it, and good.  The most effort, I think, is writing all the stuff.  Ah...  So, the summary, what's the most important you need to consider?  It's the deleting duty.  It's the remote access.  It's the pseudonymization.  And this is information duty.  That's the most important point you need to consider.  Ah...  This information duty, half of them you already have from German law at the moment  when you did it, when you didn't did it.  So now you really should do it.  Pseudonymization, I guess, is most effort for all.  And remote access, yeah, most have it anyway.  Usually when I'm a customer of a company who provides something online,  I can change my data.  I cannot even read my data.  I also can change it.  The deleting duty, because we have in Germany, at the moment,  you should delete, but when you can't delete, you can lock,  and most companies just block.  There are lots of companies where even is the...  You can't remember that.  They think it's very difficult to delete even when it's easy.  So what's difficult to delete is a feeling, yes?  How does this...  I was reading a draw.  You go where, for example, I did this, so you have like...  I'm not sure you're logging.  Logging with G.  Yes, so what's that I did this to...  You can see once a bubble wall is going in,  logging out in my...  It's long, it's simple, whatever.  What happens to that kind of...  You are not allowed to...  You are generally not allowed to control your employees.  For example, or...  If I have to cost-review by something from my company, I might be in a get request,  so I'm giving this into my log data analyzer and it's not for something I can never delete out.  So does it apply to logging to security?  No, you would not... There is no law for this,  so you are not allowed, without my allowance, to store that anyway, to store that in any kind.  Well, I might have to because I'm in a  banking regulation.  No, no, sorry.  When I said there is no law, of course, there are bank secret laws,  there are some laws where they have...  Like banks have own secret laws, churches often have it, health companies, yes?  If you are...  You have to service your employees,  so you are not allowed to collect dogfights,  but you are not allowed to analyze them for statistical purposes also.  Use dogfights to check on your employees.  You are not allowed to use dogfights to keep up.  Yes, but if the customer requires information, the owner requires a commission of all data and storing it out.  Yes.  So when I have the data in my log aggregation,  it's like, well, it's just not possible to...  Yeah, exactly.  That would change the knowledge to have statistical purposes,  from the company of the state,  to your data, if you are able to go back to the person you just know they are from,  you can have it anonymized,  without any other people, without any user names, without any possible error.  Exactly.  You can use it as a statistic,  but not if you are able to go back to the person you just know that,  not about the stock data, not about the data.  Statistics should be...  It's a well-worked case.  Sorry, but not now.  Yeah.  So, the question is...  Now, in any case, statistical data needs to be minimums for an individual.  So, the question is,  how do you...  How do you...  How do you...  How do you...  How do you...  How do you...  How do you...  How do you...  In any case, statistical data needs to be minimums for anonymized.  You are not allowed that you can...  So, the same for health data, for example,  you always, when you have statistical data,  they have to be anonymized.  And in that case, they have to be anonymized.  Because you have no law, no right to do it.  There is no law that...  Besides banking or so, but in standard use, you don't have a law for it.  And then you are not allowed to do it.  It's very simple.  And when they...  So, your customer also can say,  okay, you start my IP address,  you didn't ask me for it,  and then you have to pay the penalty.  He can go to the officer and say,  hey, here, look.  And what's also allowed  is that not only the person himself  can go to the officer.  That's at the moment.  Or, no, I don't know if it's still at the moment.  I don't know if that's the German law.  So, there can be organizations  going against you, like Verbraucherschutz.  They are allowed to complain about you at the officer,  and then the officer also will get your penalty.  So, at the moment, as the old law was,  that only the person who...  the person himself and the data protection officer  were allowed to complain at the officer.  But there is a new German law that says  that also organizations like Verbraucherschutz can complain.  And, yeah.  So, what is the deletion duty  with backups?  So, if you have a backup or database  which you keep around 15 a month,  but then someone says,  I want...  right, the deletion duty comes into play  because...  So, a month is not a problem anyway  because three months is minimum for what the English word  and post-frist.  I forgot it.  Redention.  Yeah.  And so, a month is not a...  And usually, at the moment,  the officers say,  the deletion year is okay.  So, that's...  But that's not in the law.  That's how our judges decided and they said  when you delete and remove all by end of your...  your business year, it's okay.  But the three months you have anyway, so...  So, it's not immediate...  Yeah, of course.  Of course.  The law says immediately,  means after the...  I still...  Potential time is over.  So, you have the three months  and judges are a little bit more...  Okay.  Latest at the end of your business year.  So, yeah.  What about archive systems  which are particularly protected against deletion  because there is no laws...  For instance, banks must use archive systems  which are particularly...  There is a law for it, also for health services.  Okay.  So, you have...  Did you sign a mis-ation?  Yes.  Anyway, for...  Yeah, you need to...  So, when you have archiving law  without deletion...  Anyway, when you have a storage or archiving law,  then you need to pseudonymonize.  The customer kind of asked to...  No, because there is the law that you need to archive it.  And for health, of course,  you need to pseudonymonize already before,  but on other data,  you need to pseudonymonize when you start archiving.  Hmm?  The question was already asked,  but I would like to bring it up here  just for...  Because I didn't quite get it,  there will be a reliable way to find out  is this big personal information yes or no  without it being kind of debatable.  I guess when we want to...  You know, for laws, it has to be kind of...  So, it's definition of what is personal data.  No.  It's...  Yeah, it's pretty clear what is personal data.  The question is what is personal data?  Personal data are all data that belongs to you.  So, or, Hannah, do you have...  Completely. ...kind of data which describes you  or is there any truth identifying you as one person...  Yeah. ...in a group of...  Any info... ...for people that only one has glasses,  then the information you are the person who is wearing glasses  is the thing of information which identifies you.  Yeah.  So, to make sure that any kind of information you have  is not able to identify another person  and say no data...  to identify any person that's not a personal data.  So...  And now say this...  The problem is that three weeks of day...  No, no.  Now, you have...  That's exactly...  So... ...a lot of people just call my question  because it's my question.  Let me first repeat for the camera.  So, any information with which a single person can be identified...  The example was when you have a group of people  and just one is wearing glasses,  then it doesn't matter how big the group is.  So, the one of having wearing glasses always can be identified.  And for...  And...  It needs to be minimum for people or three and more.  It's my information that you can't identify...  With same information,  where judges say it's...  You can't identify a single person anymore.  So, when you have a group of four people wearing glasses,  then it's okay,  but when you just have a group of 100 people wearing glasses,  then the person with glasses is clearly identified.  Yeah, your second question.  Thank you.  My question is actually as of before,  this is, I guess,  with this kind of definition,  as it's called out,  we could infer things.  So, with the advancement in AI and machine learning,  we see sometimes the serenity effect.  So, we thought there's no link there,  but then at some point, the link is...  Yeah.  So, at that point, that becomes sense.  Exactly.  So, if you're in a company and you have to invest it in something  that faces all these information,  you're not facing the...  So, for companies, it could be kind of like,  what am I allowed to store at all?  I'm facing every kind of question.  So, I guess that's kind of the point that I was putting forward.  You're only allowed to store when you really need the information  for the business.  You make a simple example.  You have a person in a true wearable,  a true wearable, a white one,  a white white one,  the person with glasses,  the person with glasses is unfortunately identifiable.  So, you don't need to ask people,  or you don't need to delete it,  you can store it as much as you want.  You can store information, the person with glasses,  it's also not identifiable.  You don't need to put it in a white one.  No, because you don't...  You don't combine it together, just store it separately.  Yeah, when you don't have any other further information,  the person's wear a green t-shirt,  that's not personal information,  but when you have the names of the persons,  green t-shirt, green t-shirt, green t-shirt,  then of course you know who wears green t-shirts in your data set.  I don't need a name.  I can try to call the person's activity  under the tag  who wears glasses and wears black.  So, I don't really need a name if I want to identify the person.  I mean that I identify persons by two different characteristics.  Each one of them is not...  Yeah, but you need a second when you just have...  I'm going to put the other one in the phone, please.  Yeah.  When there's no other information just  persons with glasses and without glasses,  you don't know who...  And when you have 3,000 customers,  you don't know who wears glasses.  Oh, 5 minutes, okay.  Yeah.  You said you used to request the definition of state  as a regulator as well,  or could it be anything like a phone call or email?  Anything?  Email is difficult because...  Email always is difficult because  email always you have a combination of two persons.  Because it's a chat between two persons.  So, both persons have rights.  I'm not sure if I understand.  Let's say I have a...  So, I want to request that the shop is debuting my name.  So, the shop has its email address somewhere on the website.  Yeah.  Is that allowed?  Yes, of course.  And they need to do it.  They don't need to delete data where they are  who are right that they have to store them.  And what was that?  Pretension.  Yeah.  Pretension or...  Yeah.  Where you keep the information.  No.  You just can...  No, there must be an easy way for you as person  to ask for it.  So, they have to accept it in written form anyway.  No, it doesn't matter if email or not.  So, no, not anyway.  They need, of course, they need to make sure  that you are the person to whom the data belongs.  So, that is something to identify you as the data owner.  But, no, it has to be a very easy form  and it has to given in this information  you need to give the person anyway.  So, yeah.  Yes?  I've got two questions.  First of all, what happens with this data in cloud  like Amazon that can be moved without your consent  or notice from area to area?  For example, it can be moved from Frankfurt to some other region.  So, what happens with data in cloud like Amazon?  Like Amazon is an international organization,  it's a party.  It's even worse.  Yeah, yeah.  In my case, I'm buying things in Germany,  in the US and in India.  So, in India, it's mandatory for the Indian organization  to comply with this or they don't...  No.  Imagine the...  That's exactly the European law just for you.  Yeah, but I mean...  That's why...  Is the US have to comply with that?  Is the UK going to comply with that  when once the Brexit is done?  Or...  We don't know.  We don't know.  Yeah.  How do you get that information outside?  Okay, Great Britain has stated that they will comply to...  Yeah, and... ...the market.  But when you run a business, it's your part to ensure  that your company's purpose and office.  Exactly.  If you come from church or meet Microsoft Office,  that allows...  Whenever you're here, he says,  anyone based in the EU or anyone pending a target  in the personal data will be you based in the EU.  Yes, exactly.  EU?  No, no, no, there's no...  That's why...  You're not just in the EU based in the EU.  So, the law just belongs...  It's for you.  That's why you need to point out  that you will give you the data out of the European Union.  And there are no way in Switzerland belongs to it too.  That's a special...  And, yeah, as he said, UK too.  So, I want to wait what UK still is you.  But there was a question and there was a question.  And we have five seconds, I think we can...  We have talked about the European directive,  but which countries do you think have actually made it wrong?  What?  This one was the other one that the European Union directed,  but they are not automatic for every country.  So, which countries...  All European Union countries.  Is it or an occurrence?  Yeah.  And you had a question.  Someone who is not a EU citizen.  Yeah.  Always laws protect them if the data is stored in an EU...  Yes.  The law also, of course, would for...  Protect not European citizens as long as the data  and the businesses is in the EU  and you are living in the EU.  So, it protects you as every European people.  Yeah.  We have to stop.  58 seconds after...  Okay.  Thank you.  Thank you.
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