[wp-trac] [WordPress Trac] #43545: Helper functions: Anonymizing data in a standardized way

[WordPress Trac]

#43545: Helper functions: Anonymizing data in a standardized way
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 Reporter:  dejliglama        |       Owner:  azaozz
     Type:  enhancement       |      Status:  closed
 Priority:  normal            |   Milestone:  4.9.6
Component:  Privacy           |     Version:  trunk
 Severity:  normal            |  Resolution:  fixed
 Keywords:  needs-patch gdpr  |     Focuses:
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Comment (by sgreger):

 Replying to [comment:20 azaozz]:
 > Replying to [comment:19 pputzer]:
 > > Have you got any source for this? I know of no such ruling and have
 not been able to find any German article that mentions it. All German
 articles on the topic of IP anonymization seem talk about killing the last
 octet (or using Google's standard `_anonymizeIp()` function).
 >
 > Somebody mentioned this few weeks ago in Slack (I think) but can't find
 anything more about it either. Thinking we can consider this as "not real
 unless proven otherwise" :)

 I am not aware of any court rulings, but the consideration about a
 potential requirement of cutting to only the first two octets (IPv4) may
 stem from the EU Article 29 Working Group's
 [http://ec.europa.eu/justice/article-29/documentation/opinion-
 recommendation/files/2008/wp148_en.pdf Opinion paper WP148] (2008):

 ''"Currently, some search engine providers truncate IPv4 addresses by
 removing the final octet, thus in effect retaining information about the
 user's ISP or subnet, but not directly
 identifying the individual. The activity could then originate from any of
 254 IP addresses. **This may not always be enough to guarantee
 anonymisation**."'' (emphasis mine)

 The "Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein", one
 of Germany's 16 Federal Data Protection Authorities references that text
 in their [https://www.datenschutzzentrum.de/artikel/575-IP-Adressen-und-
 andere-Nutzungsdaten-Haeufig-gestellte-Fragen.html FAQ on IP addresses (in
 German)] to suggest obfuscation of two octets as acceptable.

 This is the opinion of public advisory bodies on data protection, not
 binding law; deleting the last octet appears to indeed be common practice
 in Germany, though some sources (legal blogs, mainly) tend to recommend
 deleting two. Since privacy compliance is always about minimising risk,
 not absolute rules, I believe that at least a filter to set a higher
 anonymization level could be worth considering?

-- 
Ticket URL: <https://core.trac.wordpress.org/ticket/43545#comment:47>
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