Wednesday, 7 March 2018

Re: More diagnostics data from desktop

On 7 March 2018 at 11:46, Jeremy Bicha <> wrote:
> What proposed collected data do you think should be considered
> personal data for GPDR purposes?

I am a long way from being an expert on this, and the more I research
the more the ground seems to shift. You would need to seek legal
advice. I was certainly hoping that someone with more knowledge would
have jumped in by now!

When I wrote the email you replied to, my understanding was that
because it might become possible to correlate anonymised telemetry
data with bug reports etc (for which user details are logged in the
form of a user account) there was definite potential for them to get
swept up indirectly if not directly. Subsequent research suggests that
it might simply be required full stop, or only in certain
circumstances, or maybe not at all. None of the resources I found were
clear or authoritative enough to be worth linking to.

Therefore the biggest problem seems to be a lack of clarity. A quick
Google for "GDPR telemetry data" certainly gives no clear answers. One
option would be to pay someone to get clear legal advice and keep that
advice up to date. But the "informed opt-in consent" option seems a
lot easier.

Mark Rogers // More Solutions Ltd (Peterborough Office) // 0844 251 1450
Registered in England (0456 0902) 21 Drakes Mews, Milton Keynes, MK8 0ER

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