I’m confident that compliance is:
- Straightforward for any non-tech firm;
- More complex but not that hard for most tech firms that handle data;
- Far more complex for large organisations than small ones;
- Basically only a real problem for fly-by-night tech companies that want to operate by reselling personal data.
I’m not sure what your motivations are it making it seem disproportionately burdensome to comply with, but I don’t think they’re good.
I wonder how people from other parts of the world are understanding this and how do they look to the site like that? I mean, this legislation that is designed to protect people and their data is making them such a problem to rather block roughly 500 milion people. I personally would have a huge trust issue, but this is not about me, what do non EU, who don't run any site (conflict of interest) guys think?
I would for instance rather put a huge mark on all pages "GDPR compliant, protecting data even for non EU visitors" or something like that and try to get some money out of that. But that is just me.
- What did you do about logs? Things like request logs will at least contain ip address which is PII. Now logs can be cleared after a fix interval but the time for honoring the data delete request is a month I guess. If you want to keep logs for a period more than that, what do you do? If you anonymize IP , it makes other analysis on top of those logs useless.
- What did you do about data backups? - What did you do about external error reporting services? - What did you do about analytics services?
Regarding backups, realistically you are not going to have to delete data from them, as it's completely impractical to delete only data for a particular user from archive. If a user requests their data to be deleted, delete it from the live site and be open with them that some data will remain in archive - securely encrypted and untouched - for your defined retention period.
Regarding analytics, we use Google Analytics, which uses IP addresses to guess location, but doesn't make them available in the admin site - so GA doesn't actually give us any PII. As such, we simply reworded the privacy policy to be more easily readable, so it's completely clear what data we collect and why. The forthcoming Privacy and Electronic Communications Regulation (aka ePrivacy Regulation) should provide some clarity if anything else is required, but it seems likely that simply having cookies enabled in your browser will count as consent.