[wp-trac] [WordPress Trac] #43492: Core Telemetry and Updates

[WordPress Trac]

#43492: Core Telemetry and Updates
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 Reporter:  xkon              |       Owner:
     Type:  enhancement       |      Status:  new
 Priority:  normal            |   Milestone:  Awaiting Review
Component:  Upgrade/Install   |     Version:
 Severity:  normal            |  Resolution:
 Keywords:  gdpr 2nd-opinion  |     Focuses:
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Comment (by DavidAnderson):

 @idea15, Rob was talking about the data processed by the WordPress
 foundation when it receives incoming HTTP requests for updates information
 - he wasn't talking about end-users of WP self-install getting data out of
 the those individual installs. There has to be something on wordpress.org,
 so that people can request PII that is still stored after individual
 installs are wiped.

 > Also, remember the RTBF is the right to request it. It is not an
 automatic, universal right to have it done.

 It's true that GDPR does not grant an absolute, limitless right - for
 example, if someone requests deletion of all their PII, then potentially
 a) it could instead be anonymized (under the GDPR, that requires that
 there's no way to reverse the anonymization, however difficult the
 procedure to do so) or b) another law might require retaining it (e.g. tax
 records). In the case of the sort of stuff wordpress.org is storing -
 quite a bit of information on the details of each site install, indexed by
 URL (certainly PII in many cases) and also IP (which would allow
 identification in a lot of cases using "what site is hosted on this IP?
 tools combined with simple scans of installed plugins/themes) - in the
 case of this info, anonymization or complete deletion would be the only
 possibilities. There's no general exception to arbitrarily say "no, I
 don't want to delete or anonymize your PII, so I'm not going to."

 In the UK, the authoritative state body for implementation of the GDPR is
 the ICO. Their guide is here: https://ico.org.uk/for-organisations/guide-
 to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-
 erasure/ . There, the permitted grounds for refusing a deletion request
 because you still need to process the data for a legitimate reason are
 given as:

     * to exercise the right of freedom of expression and information;
     * to comply with a legal obligation;
     * for the performance of a task carried out in the public interest or
 in the exercise of official authority;
     * for archiving purposes in the public interest, scientific research
 historical research or statistical purposes where erasure is likely to
 render impossible or seriously impair the achievement of that processing;
 or
     * for the establishment, exercise or defence of legal claims.

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Ticket URL: <https://core.trac.wordpress.org/ticket/43492#comment:47>
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