We're not fragmenting the internet by looking after our own interests. This wouldn't be an issue if Americans viewed rights (and in this case privacy rights) as belonging to human being as opposed to Americans citizens. The US's policy is what led to this:
> Agencies shall, to the extent consistent with applicable law, ensure that their privacy policies exclude persons who are not United States citizens or lawful permanent residents from the protections of the Privacy Act regarding personally identifiable information
We had PII on Azure. We wanted to do business in France. We had to fork our services, and run a full stack on a crappy provider in France. They charged a lot more, would take weeks of vacation with zero support for us. It was a freaking nightmare.
EDIT: I love the responses I'm getting. People are in absolute denial that this does in fact fragment the internet. You may believe that's a good thing, and that's a rational discussion we can have. But don't lie to yourself, or to me, that this doesn't fragment the internet.
We didn't fork our code, we forked our services. We ran everything on Azure. Then we had to configure our kiosk devices to either talk to Azure, or to talk to our servers in France.
"Did you write your service to use proprietary Azure APIs without regard to vendor lock-in? Why not take this as an opportunity"
I'm sorry, do you have any idea of the cost of doing these things?
If you have 6 developers, total, how many of them are you willing to allocate to rewriting your stack, so that you can sell your product in Europe?
Oh indeed yes, which is why for years now I've been warning people to not write to proprietary APIs in the first place. It's a faustian bargain and sooner or later the bill is going to come due! If not because of legal requirements, then because MS or Amazon saturates the market, and has to increase revenue somehow. This is an example of where an ounce of prevention is worth a pound of cure. The upshot is that ignoring the warnings of people like me was a mistake.
(It's funny how people have moaned for years about "vendor lock-in" WRT Oracle. "They charge for every core!" But the cloud providers charge for every invocation, which is infinitely worse. And yet no-one seems to worry about it. It's really odd.)
But thanks for lecturing me that "vendor lock in" was what killed our 6-developer team that was developing hardware, and computer vision, and 3D computer graphics, while developing a health care product under the tons of regulation that comes with that.
Your arrogance is just stunning.
I think it's important to warn "parents" (or future parents) to avoid this particular tragedy, which I think is quite avoidable. I want to encourage people to question the orthodoxy around cloud, that everyone is doing it so its fine, and worse is better anyway, yada yada. It may be insensitive to use your situation to illustrate the downside of cloud vendor lock-in, but my motivation is not to look down on you, but to warn others about this very real, very painful outcome that they court when they make the popular choice.
We happened to not use any vendor-specific APIs.
And it still killed us to fork our stack, and to teach our kiosks to be able to talk to the right server, and the extra cost of the servers in France, and the lack of support we saw from the provider in France...
It's embittering, hardens the heart, and makes you want to give up, but you've gotta redouble and bust through it.
And by all means, shame the provider if they didn't live up to their end of the bargain.
Sorry if I don’t follow your reasoning, I’m still stuck at this piece of USA policy you seemed to have glossed over:
> Sec. 14. Privacy Act. Agencies shall, to the extent consistent with applicable law, ensure that their privacy policies exclude persons who are not United States citizens or lawful permanent residents from the protections of the Privacy Act regarding personally identifiable information.
https://www.govinfo.gov/content/pkg/FR-2017-01-30/pdf/2017-0...
Just as France accords its own citoyens rights that foreigners aren't entitled to.
"We're not fragmenting the internet."
???
Ok, let me make a simple “marvel comics” example: what if all your calls were funneled through “Putin servers” or “Iran cloud” or “ People's Liberation Army computers”? Would you mind?
I hear you arguing “but we’re the good guys! We’re USA, flag bearers of Democracy!” but no. Really according to EU law, under USA jurisdiction Pricacy Rights are fair game for people like Zuck. The guy that said “ I have over 4,000 emails, pictures, addresses, SNS. People just submitted it. I don't know why. They "trust me". Dumb fucks.”
Now, granted: our politicians likely want to stay on top of the consensus forming media, and make sure it’s within reach of their network. Annoying to see all the action moving to a different platform after all the years spent building relationships with the old media, but that’s the business.
When I found out Parler was being hosted on Russian servers, I immediately informed everyone I knew who was thinking about switching to Parler that it was a really bad idea. And it's their choice whether to use Parler or not.
I think it's great if companies can't hide that they're doing something like routing data through Russia. I think it's pretty stupid to not let someone use a product that routes data through Russia.
I also think that if Facebook stands up servers in France, it'll still be just as problematic as it is today.
In the end, though, there is a high-tech solution here, and that's to migrate to 100% asymmetrically encrypted messaging, at the application level, regardless of underlying transport. This would force nation states to risk large scale hacking of devices, but that's more visible and easier to combat, as long as we remain free to make (and buy) the compute hardware we want to make.
His whole comment was about how he want to let traffic route through Russia even though he doesn't like it... but it's really Americentric? Could you explain that point please?
Then there’s the cost of your devs implementing the same feature azure and aws already has, which is usually forgotten about.
Also the icing on the cake for oracle was a contract termination fee. No cloud provider comes close to the oracle billing nightmare.
Nothing comparable to AWS/GCP/Azure.
GCP should open one early 2022.
Basically the US government says it gets free access to all data stored by any US company or its international subsidies anywhere and that non-us-citizens have absolutely no right to any data privacy at all.
However european citizens do have such a right, and as such, companies can not process personal information using american subprocessors, because those can not guarantee to respect the citizens rights.
For a long time this was all about some contractual clauses between processor and sub-processor: the american subprocessor guarantees by contract to respect the data subjects fundamental right to data privacy.
And then the USA made the CLOUDA and FISA and all those contracts are no longer worth the bits they are encoded in. American companies are by law required to not respect the right to data privacy and can not guarantee to respect it in good faith, as they are themselves subjects of a surveillance state.
Now look at how AWS reacted to this problem: they added new clauses to the contract with their european customers, in which they promise to challenge law enforcement requests, especially those that are overbroad.
When EU goes after FAANG like this, it pushes them to position themselves against mass surveillance and in favor of a global basic human right to data privacy. In my honest opinion this fight is very necessary and i can only hope that humanity wins against surveillance capitalism in the end.
The colo/managed provider they chose and had been working with for years was nigh incompetent. I was positive that being able to spin up infra in any of the clouds would have been a ton more reliable.
Imposing byzantine regulations on every webmaster on the planet isn't helping anyone, least of all the European user, who will increasingly be locked out from the rest of the planet.
The EU consumer will end up with strictly worse solutions and all the rest of the world will “gain” will be the crappy trade-barrier-supported Euro versions of Google and Facebook.
I see very little advantages from these privacy laws but I use and appreciate US businesses every day.
Still, the "please let us track" popups can be fixed by policy or law, and I hope they are.
Lots of loaded assumptions there, of course, starting with the first conditional clause.
It's not fragmenting the internet; fragmentation is the whole point of the internet. It's (re-)decentralizing something that has been decentralized the whole time, until these gluttonous whales decided try to eat the whole pie.
And you're convinced that embodies "the whole point of the internet"?
Decentralization of the cloud is a good thing for so many reasons. I think you're deliberately confusing it with your PII issues and not grasping the larger picture.
You are raising the barrier to entry, limiting competition.
Competition is good for so many reasons. I think you're deliberately ignoring the impact on small companies and not grasping the larger picture.
It's always a tradeoff between racing to the bottom and stagnating. Both are bad, both hurt consumers, and this seems like a good balance between them.
Does that seem like a good balance of needs to you?
The technical difficulties seem so entirely solvable, in time (and with that competition you mentioned). Right now it's easy to deploy servers across tons of instances. In the future, if we need to, we can build analogous solutions to the problems you're talking about.
And where we can't build our way to easy solutions, that's fine. Those cases are probably the ones where there are legitimate local differences in what's acceptable, and I want locals to be able to decide that for themselves. It's an absurd goal to try to make it easy for six engineers alone to scale to the entire planet.
That's an interesting assertion. As counter-example to that assertion, [gestures at huge amounts of the internet as we know it, which was started by small teams.]
And I'm not talking about scaling to 7 billion users. I'm talking about scaling to all of _my_ users, even though they live in dozens or hundreds of countries.
If that means I don't get your business and I'm worse off for it, I'm happy to have my laws changed. Or maybe someone else will come up with the same service who does follow the local law.
You're basically discovering something that physical stores have had to deal with forever. Gary's International Store of Chainsaws and Weed knows that it can't sell chainsaws in jurisdictions where chainsaws are illegal to sell from stores. The people of that jurisdiction made the decision that chainsaws should not be sold from stores; Gary doesn't get to ignore that. Instead he has to incorporate the fact that not all stores get the same inventory in his logistics.
If that means Gary refuses to open his stores in such jurisdictions at all, that's fine. The people of the jurisdiction can decide whether they're happy with the outcome and change their laws if they're not.
Forcing me to run servers in France is absurd.
If anything, it increases the attack surface and makes it more likely that private data is exposed.
He has the right to object in any case. That's free speech. But despite all his objections, he either does his business respecting the law or doesn't do business at all.
It's funny that you think that such a law would be absurd, when laws that require a store to sell locally-produced goods over imported ones also already exist in the real world.
>Forcing me to run servers in France is absurd.
You're welcome to think that. Don't run servers in France then.
Hence my original comment: The internet has spoiled us by making it so easy for a while.
What's a very long time to you might not be a very long time to me. GDPR wasn't a draft when the product I'm talking about first launched.
The Azure offering did not exist when my small team needed it.
We helped manufacture medical devices. We sold a device that took medical images, and then sent the images to a server. The server would do tons of processing on the images, and help manufacture a medical device custom to the patient.
We ran our servers in the United States.
We could not sell our product in France, until we stood up servers in France to store and process the data.
Why would we do such a thing? To provide excellent healthcare to people. Even ungrateful French people. Our product was lower cost and higher quality than our competitors, with better patient outcomes.
What monsters we were for running our servers in the U.S., right?
Other people exist and have rights. It's about time that people assert their rights over data that is absolutely consequential to their lives, instead of being tiny pawns of companies who treat them like a highschool science experiment with live ants.
The idea that storing your data, encrypted at rest, on spinning rust platters inside your country somehow makes it safer than storing that same data, encrypted at rest, on spinning rust platters inside my country, is bizarre to me.
But that's fine. I think giving you the choice makes tons of sense. I'm not saying France should have a law forcing all data to be kept in the US. I'm saying it's bonkers that I cannot offer a product in France that happens to store data and process data on a server in the US. Even with a waiver. French citizens do not have the right to let their health care information be stored on a server in a different country. (As I understood the laws, at least - perhaps our legal representatives were misinformed.)
If you want control over your medical data, then I'm sorry, none of the existing tooling does what you should actually want it to. It should be stored on systems you designate. Not on some lowest-bidder French server that has unknown security practices.
It's amazing to me that you're lecturing me about other people's rights, when you're literally denying French people the right to buy my product, unless I meet some ultimatums. I'm not denying them, you are.
And you talk about consequential to their lives? My product lowered costs and had better patient outcomes, and we couldn't sell it. Maybe try a different argument.
At some point in your project there seems to have been a time, when such basic questions of consent were overlooked and later you paid the price. Your intentions may have been nothing but good, but I for one am glad, that such practice was not allowed to happen.
Walk me through exactly what you would like to happen.
If you think the best outcome is that only radiologists who live in country X can look at your medical images, then please really think about what that means for under-developed countries.
Please also think about the fact that people have medical imaging exams 24 hours a day, and think about where radiologists live and sleep.
The next time you get a CT scan and have to wait 4 days for the results, you'll know that your hospital system doesn't have teleradiology.
We absolutely understand patient consent, and then France started establishing laws that denied patients the right to consent to having their data transferred to the US. (As I understood our legal representatives, at least.)
(For the record, in case it's confusing to anyone following along, I worked on half a dozen different medical products in my career, in different companies, in different parts of the body, in different modalities, etc.)
My guess is, that they want to avoid the situation entirely, in which a doctor (or other people in the hospital or other institution) has to ask the patient for their consent for such a thing. It would come down to things like framing, for example: "The best people for x are in country y.", which might be true or just opinion of that doctor. There are issues with this:
(1) Usually the doctor is not informed about these data protection issues themselves. Usually the doctor did not also graduate in some mathematical / statistical / data science subject or following along the various data protection scandals. Most of the doctors probably have other things to do. Just like the rest of the population is mostly not well informed.
(2) We probably don't want a situation, in which the doctor dangles a carrot (the best people are in country x) in front of the patient, luring them into consenting.
(3) Doctors want to get their work done. They don't want to have to ask every patient for consent for things outside of their own expertise. Even if you transfer the paperwork to someone else, who will want that additional workload? Also the people going to a hospital might not want to have to deal with that stuff.
(4) What is the legal side of this? For example say you send data to the best experts in another country and you get a misdiagnosis and operate based on that. How does this work?
I think it is possible to keep data generally in France for example and only have the experts look at the data via conferencing tools. Then the experts can be made aware, that obviously they may not share any of that data with anyone and that they can only look at it, while it resides in France. For that we need a secure conferencing system, which is not run by big corp living off selling data directly or indirectly. We need capable tech people in the right place to set things up. We might also need Computer literacy on higher levels for the experts.
Tell me you were at least running anonymisation software in hospitals before you transferred?
We don't do it for fun. This is a part of patient care.
Radiologists awake in Australia can read images from the United States. It saves lives.
The radiologists are licensed and certified in the hospitals and states.
And by the way, if I get a CT scan of your head, I can trivially reconstruct your face. Might even recognize you with it.
If you want to freak out, medical records are sent by fax machine ALL THE TIME.
I am truly interested in this since I am in EU and use Azure for similar processing.
So blaming the GDPR and new rules, seems a bit weird in this case.
Now, consumer protection regulation is always a balancing act. And most consumer protection laws will hurt some companies that didn't actually do anything bad. That doesn't mean I don't want any regulations. Particularly when it comes to healthcare.
And my real concern was people who want that cake, and also want to pretend they're not "fragmenting" the Internet. I wish people would call it what it is.
Heh. Somethings tells me a devops engineer in France has way better work-life balance.
So then Hacker News has to launch servers in France.
And then French HN users are in an island, and only see other French HN users' posts and comments.
And, to be clear, you think that's a good thing?
Maybe this decision makes France toxic/favorable to certain kinds of business--much like how many privacy companies operate in Switzerland because the Swiss government is less likely to snoop than certain others, or how advertising companies operate in the US because they'll let you do whatever you want to their citizens. So yeah, fragments.
But you as a user are free to opt-into any fragment of the internet that will have you. If your government wants to stop you from doing so you should either take it up with your government or circumvent those limitations.
I don't particularly like the kind of fragment that France is creating here, the notion that data has a physical location in space strikes me as a rather shaky one, and I think policies following therefrom are likely to create convoluted architecture that exfiltrates the benefits of access without exfiltrating database instances (I've written enough code that tap-dances around the GPDR to know). Since I'm not trying to start an ad supported business in France, though, I'm happy to respect their right to come up with whatever weird policies they want.
I love hackernews, but there’s way more world out there to discover.
This is protecting EU citizens from EEUU companies having a free lunch on their data.
I enjoy communicating with all HN users, across the world.
If we each had to use only our own country's fork of HN, we wouldn't communicate with each other, and that would be a bad thing.
Or was it before Azure had that? Looks like they’ve had it for awhile, at least back to 2009 or 2010.
This was impacting us in 2014 to 2016, as I remember.
I'm sorry your business was impacted during the period where the regulations came into effect and the big platforms did not have compliant services ready. It would have been better if the negative externalities of these regulations would be entirely carried by the big platforms who are responsible for consumer privacy in the first place.
But in any case, the point is that the issue is solved without changing the laws or people having to switch cloud providers, as simply the global cloud providers have started offering compliant services.
In the past people said that the Internet was made for porn. Today the Internet is seemingly made for advertisement and surveillance. It not strange that so many people who worked in this industry for decades are feeling a bit lost in this new horrifying industry, which if the Internet really is made only to do advertisement and surveillance, I honestly think humanity is better off without it.
You should support companies with the best behavior.
I worked at a company that enabled a radiologist in over country to do a preliminary read of a CT scan performed in another country.
Cutting the amount of time for a CT scan, and even connecting a CT scan with a radiologist who specialized in that particular kind of scan, we saved lives.
And yes, there's also furry porn.
It's a tool.
I feel like I'm trying to convince you that BOOKS are good, despite the existence of hentai.
So why didn't you use Azure resources in Europe instead of "some crappy provider"? Sounds like you made a rod for your own back. If our clients are happy with Azure (in the right region) then I can't imagine many in the EU (other than perhaps national security services and their suppliers) reasonably refusing to allow use of it.
We host in Azure for some pretty significant financial organisations, mostly UK based but spreading our area. Some companies are requiring us to fully host in Azure DCs in their region, and some of those are Eastern, not UK/EU, based companies. At least one US interest that a friend's employer supplies demands data about its employees be hosted over there rather than over here, presumably so they can be assured it is kept to standards they are locally required to follow. Is it wrong that way around in your book too?
It isn't as easy as having everything in one region of course, but not much harder nor massively more expensive (caveat: most likely, as far as I know, I have the luxury of ignoring the bits that don't interest me and money is often one of those things, but I'm also senior enough that if there was something expensive happening, or something not happening due to expense, I'd catch wind as it would affect things I need to plan around) and it can't be as faffy/costly as using different providers in each territory.
If you are correctly following relevant regulations everywhere this does not fragment things any more than other rules that already existed. Aside from the fact things are being enforced this time, forcing companies handling PII to not quietly do things wrong because it is inconvenient to do things right. As an individual I'm perfectly fine with this.
https://news.microsoft.com/europe/2020/09/30/our-commitment-...
The company failed - it is what it is, and it sucks for the team - but you can't blame the EU protecting privacy/rights for bad business.
It took some doing which was the whole point. The local provider even got a chance to match the offer.
Looking at it from this angle, it seems perfectly reasonable for the EU to dislike the specifics of the analytics use case while still being ok with something like Google Docs.
But that's not what CNIL is basing their decision on: "The CNIL concludes that transfers to the United States are currently not sufficiently regulated...Indeed, although Google has adopted additional measures to regulate data transfers in the context of the Google Analytics functionality, these are not sufficient to exclude the accessibility of this data for US intelligence services."
I probably don't understand the legal issues fully, but it seems the worry is that US intelligence services may be tapping the lines and databases of Google, may have agents working at Google as badged employees, or may be able to subpoena Google (or any US service provider). [for the record, I wouldn't doubt if all the above are true]
I don't see how Google Docs is less susceptible to Google tracking user activity (and by extension US intelligence).
> "CNIL recommends that these tools should only be used to produce anonymous statistical data"
So the tools are not anonymous because the request headers of the client are being logged and used to identify a session, along with what resources on the site were accessed in that session.
Any site operator has this data on their visitors.
CNIL doesn't want sites hosted in France to be making client-side calls to services provided by Google (whether analytics, fonts, etc) or theoretically any US-based service provider because the client request will be logged by that resource host and open to access by US law enforcement? Do I understand that correctly? What's the solution? A site builder can't let web clients make direct calls to any resources in the US? That seems... sweeping, profound, surprising, impactful. Have fun with that.
No need to dig so deep: IP addresses are considered private information under the current EU law, meaning that just opening a client-side connection somewhere leaks that data to that somewhere.
> I don't see how Google Docs is less susceptible to Google tracking user activity (and by extension US intelligence).
There is none. The difference is that the website studied in the ruling was not including resources hosted at Google Docs, and hence no mention of it. If the site embedded or directly linked to a google docs document the same reasoning would have been applied.
> CNIL doesn't want sites hosted in France to be making client-side calls to services provided by Google (whether analytics, fonts, etc) or theoretically any US-based service provider because the client request will be logged by that resource host and open to access by US law enforcement? Do I understand that correctly?
Almost. They don't want any calls prior to explicit user acceptance.
> What's the solution?
For fonts/images required to load the page, use EU-based hosting facilities. If you want to link to a google docs document, a youtube video or something like that, ask the user before following that link.
> That seems... sweeping, profound, surprising, impactful. Have fun with that.
It is, I don't think anyone is denying that. There are several things that may happen here:
1. US tech companies take it as common practice to spin-off EU-based companies that are not subject to US law and store everything in EU soil. When they don't, EU competitors pop up and EU companies use those.
2. The US passes laws that offer EU-level protections to both their own citizens/companies and (at least) EU-based citizens/companies.
3. The EU backtracks on this by adjusting their current laws.
I, for one, would really like to have more fragments to explore.
People's ideas about how their technology should serve them will change over time. I don't want to have to overthrow the old internet before we can try something new, I want it to grow with us--the parts that aren't serving us die off, the parts that address new challenges flourish. If its all one thing, subject to one set of rules, that doesn't happen.
Lucky you.
We need more Western education, not less, which is why fragmentation is a bad thing. My country of birth - in Africa - is aligned with the formerly communist nations; if they had to opt-in to a fragment, it wouldn't have been to the Western one. I might have never been able to emigrate.
Fragmentation seems like a leap backwards in time and a slap in the face of the promise inherent in the free flow of information.
Of course you are. This is the only possible outcome of any attempt to impose national rules on an international network. Instead of one global network, we'll end up with several local ones.
The internet is among the most incredible achievements of humanity. I'm glad I got to experience it before they destroy it. By now it's only a matter of time.
At the end of the day we should be doing what is good for the People and somehow its always assumed that they will/should be the ones impacted when policies like these are enacted.
But Europe has leverage here - I don't think Amazon would want to miss out on a giant market base out of some moral principle and there are probably other levers to be pulled here to encourage that.
Anyway, not adding much to your comment other than kudos.
All the big cloud providers have presences in Europe. What am I missing here?
The only people still moaning are Americans and hold-outs like Google refusing to move data.
If the EU has this much power to regulate operations that happen in America, then imagine how much worse it's going to be if you relocate your operations to the EU? In that case you actually become one of their subjects, rather than simply recording information about their subjects.
> Agencies can snoop on non-US citizens but shouldn’t snoop on US citizens
and they went and snooped on US citizens anyway.
I think the only solution would be for them to not collect and store data from GDPR jurisdictions that would violate the GDPR if they were forced to hand it over to the parent American corp.
The US parent company could not compel the subsidiary to violate the law of the region it was located in.
But what happens when senior data scientists at Google want to do some analysis? Each dataset for each global region can't remain fractured from each other. The subsidiary may not have to hand it over to the US government but does the GDPR prevent data from leaving the EU zone? If not, then local copies in the US would be exposed.
I think there would be a lot of loopholes that needed to be closed. "Will be" a lot might be the better choice if words if France's decision becomes guiding legal doctrine in the region.
I don't think Google would willing give up that data either so they could be forced to change their practices to at least get that which allowable under EU law. And I don't want to get too slippery slope in this, but that could mean privacy-minded services begin using servers in the EU as an added layer of user privacy.
And yes, GDPR prevents data from leaving the EU zone if there is then a possibility that GDPR could be violated. That's the crux of the recent court cases in Austria and France. You may not collect GDPR protected data if as a consequence of that collection there is a reasonable prospect GDPR will eventually be violated by ANYONE.
For your example case, all initial data processing would have to physically occur within Europe, performed by a subsidiary not subject to US law, and only after they had reduced it to aggregate data that could not be reverse engineered to get GDPR protected data would they be permitted to export it to America.
another 20 years and companies simply won't bother with it at all
[1]: https://fullfact.org/europe/eu-less-important-world-economy/
It’s interesting to see the pattern here: if you can’t innovate, regulate.
Maybe an unpopular opinion, but imho AWS, GCP and Azure are popular with startups because of their generous free credits, not because they are good tools for startups. As a startup you are typically better served by a DigitalOcean-level of complexity, and there are plenty of such offers in the EU (Hetzner Cloud, Gridscale, OVH, etc)
For Mailchimp you have plenty of competition, some of it in the EU (SendInBlue and Mailjet come to mind).
For payment processing there are also plenty of offers, Adyen is probably the biggest European alternative but there are countless smaller ones.
Microsoft Office 365 can be replaced by (shocker) Microsoft Office (the offline version). But most of your documents probably don't even contain PII and would be fine in Office 365 or Google Workplace. The exception is obviously email, but the market is flooded with E-Mail services from any country you like (and your preferred Hoster probably offers an email package too).
So I'm not really sure what part of the ecosystem we are missing here? European companies often have the smaller advertising budget and mindshare, but it isn't like they don't exist.
As an actual startup founder who started as a 1 man startup, strongly disagree.
Spent maybe $200 a month on Google Cloud, got an actual production ready cluster. Scaled up to Millions in revenue, never had to deal with any Linux Server admin BS.
More time on business, less time on Linux Sysadmin.
Oh, you just had to deal with a different flavor of BS. Or you was lucky and everything just worked out for you (but why Google Cloud and not some PaaS like Heroku, so you don't have to deal with cloud infrastructure/servers BS altogether?)
I've been both a system administrator, managing GNU/Linux and FreeBSD servers in the ancient ages, and DevOps guy doing all sort of stuff in the clouds. The complexity is still there, it hadn't disappeared in some magic cloud pixie dust, even though sales would wanna tell you that fairy tale. But here's the thing - you never get to dive into those waters (or hire someone to do it for you, be it an employee, contractor or paid support) unless shit hits the fan and forces you to.
You must've cheerfully walked through a minefield and haven't stepped on and even seen any mines. Honestly, I'm happy it worked that way. And hopefully, this minefield is sparse enough those days so you're a rule not an exception - I don't have meaningful statistics. It would be actually interesting to run a poll or something. I just happen to have seen a few companies/people for whom clouds weren't all unicorns and rainbows.
And as for the flavors - it just happened that you knew how to set up stuff in Google Cloud. Would you happened to know how to spin a simple instance on Digital Ocean instead and went that way, and be lucky to not encounter any serious issues, it would've been the same painless experience, just different flavor.
The big cloud providers have a variety of offerings of different complexity. Using GCP as an example: want k8s with all it's flexibility and complexity? You have GKE. Want to still run containers, but abstract away all the cluster resource management? CloudRun. Abstract away the container itself? CloudFunctions. AWS has EKS, ElasticBeanstalk, etc.
I understand people get overwhelmed the first time they're dropped into the console of these cloud providers but really it just takes a bit of reading to figure out what you should/shouldn't care about. And the benefit of doing so is enormous.
Privately I host nearly everything on a shared host in Germany (that is everything I can host without sudo) [1].
For company policy reasons I must absolutely use AWS or GCE.
For an internal project I need to setup Matomo. Something I did thrice in the last few month on [1].
OK login through SSO into AWS. Look around, ask Google, find the bitnami image, click few buttons. Done. OH shit. Now I need to somehow make it publicly available. OK. Google again. Ah this is the way. Few hours of reading and clicking later I have a publicly reachable Matomo instance. Oh hey. It warms me that it is not ssl encrypted. OK. How to do let's encrypt? Google again with my second batch of coffee (or was it the third). Found an easy way, just enter a command in the shell. Oh hey, how do I get my ssh pub key into my EC2 instance?
Damn the day is nearly gone and I have yet to deliver this tangential asset to an internal project while killing my CCI (how much I am booked on client work) for something that the first time took me 30 minutes with the great documentation from [1].
To me as a meager Data Analyst the complexity of cloud offerings is a nightmare. And the documentation is written for other echelons of tech understanding most of the time.
[1] uberspace.de
Managed K8s. Openstack.
When we started paying for it, it was still cheaper than AWS.
Just because AWS is the default, does not mean you should use it.
Disaster recovery planning is practice we should all adhere to. Hindsight is 20/20. Not trying to be a smartass. I know it was painful for a lot of folks.
At the same time, unless you paid for managed service with clear SLAs, then responsibility is yours.
Cloud is just someone else's computer.
FYI: we started with OVH before the fire
Still prefer Google, as they are the OG for k8s.
Today circumstances have changed. You need hassle free scalable DB, then AWS RDS might you best choice. Maybe.
You need open standard IaaS, well, there is ton of options.
Even before K8S, you had and option of Openstack with Ansible. Yes, very different beast, but still much _simpler_ and _cheaper_ than stocking on large number of IT professionals.
We might spend more time messing around with AWS than our colocated servers.
Whichever one let me pay rent at the end of the month
Might I ask you what kind of product your 1 man startup have?
Pros and cons to being in a crowded market.
From day 1, you KNOW there is demand for your product. You can look up Channel Advisor and see the revenue. And 20 smaller companies under fighting for the rest.
Cons of course being, you have to figue out how to compete with all of these guys ;)
I still remember arguing about bloating a web app with a 1mb package from AWS so it could use their serverless authentication offering.
Common theme as using those lambda function - sometimes paying quite a lot of them - to serve requests that would be twice as fast on the proverbial $5 linux instance.
So yeah, looking from the sidelines it feels like a huge amount of added complexity for small teams, "just in case" they need to scale. Which given how fast modern hardware is way further off than they think.
(unless they use lambda functions for every API request. in which case they better learn to scale in a hurry)
If the GUID is related to the user (like user ID), then it is Personal Information - EVEN if the GUID is random. The distinction that is easy to miss is that a User ID GUID might be very low risk (compared to, say actual User Id or user name) - but is is still Personal Information.
If the GUID is for the document (and anyone can edit the document), then it is no longer PI.
Of course, all of this ignores things like the contents of the doc. If the doc is "SSNs of my customers", well... don't do that
Also, the offline version of Office is going away, to my knowledge. I think the current boxed version is the last boxed version they plan to sell.
That’s a complete misunderstanding of the cloud’s value proposition. The point of the cloud is to have things “just work” so you can spend more time shipping features and innovating. When I see startups not using it and “rolling their own cloud” by being their own sysadmin I question the strategic decision. To me it’s generally a sign that they failed to raise the appropriate amount of capital and are therefore trading velocity and agility for cost savings.
> So I'm not really sure what part of the ecosystem we are missing here? European companies often have the smaller advertising budget and mindshare, but it isn't like they don't exist.
Also because they can’t scale within a mostly unified 300 million market like US companies can, they have to special case and deal with all special snowflake regulations in every small European country they want to serve.
Plus, that’s not even touching on the engineering talent gap.
I know we've had a lot of issues with an European company we bought; we're both using Microsoft 365 but they're set up in France. I don't think the IT folks ever figured out how to merge them (even though we probably pay a shitton to MS for support), so those folks keep using their old domain (but we can share documents and whatnot, so at least that's set up).
I would call fragmenting these things rebuilding the internet. Not sure how consolidating everyone on a few Mailchimp type services is in anyone's interest.
I think we underestimate just how difficult it is just to replicate existing services, let alone keep up with the innovation.
It's like the Argentinian effort to stimulate its own computer manufacturing by banning Apple products.
That is completely unrelated though. The only thing this ruling confirms is that you can not process data of EU residents when you can not be adequately protect them due to local laws i.e. the CLOUD act. If your laws allow you to keep the data safe, you can offer your cloud services to the EU market as much as you want. If they wanted to, the US could easily allow companies to guarantee those protections too.
I would not be surprised when, if no solution is found, some of the major cloud providers in the EU end up being e.g. japanese, israeli or canadian.
Careful, there is such a thing as network effect for knowledge. More fractured systems mean more different approaches means less aftermarket documentation means less people being able to work for you.
And that totally fine, if you think European companies have no competitive disadvantage on the global market to being forced to use traditional VPS providers or build and set up everything themselves. But I imagine it'd be very challenging if other companies outside the EU can go to market faster, deliver better services for lower cost, etc. than their European counterparts because they can use American cloud providers like GCP or AWS.
As a US citizen I've contemplated getting my wife residency down there and it's simply ridiculous - as are the hoops I'd have to go through to relinquish my US citizenship and that only matters because the US feels entitled to own me even though I haven't resided there for nearly a decade at this point. US immigration, from the working visa angle, is extremely unpredictable and only really estimable if you've got a large corporation with a whole bunch of lawyers to get your back - spousal visas aren't terrible but most come with some seriously onerous lifetime costs to execute (like taking a year off working).
I know there are a bunch of European countries and they've all got their quirks to immigrate into but you can really trivially get an EU passport and then move around within the EU.
On the other hand Italy denied my application once already, after my great grandparents basically left the country because Italy was not defending their town from Germany. They rejected my application because they say my great grandparents were not Italian but Austro-Hungarians. The lady at the consulate was super racist to my grandmother about it, in my face. After that now there's another way I could get my Italian citizenship by birthright by suing the government because of another racist thing they use to do where women were not transferring citizenship.
Again the US is not great but a lot of this things make me feel whatever "racial tensions" I may be a victim of in the US are mostly the media blowing stuff out of proportion, when most of the "racial tensions" I felt dealing with the EU are actual racial violence or discrimination that either me or my family where victims of.
That seems like a very reasonable requirement. How can you expect to participate in society, especially elections, without a decent command of the local language?
By hiring a local accountant and paying a small fortune in taxes? If I learn the language then yeah cool maybe I'll get into their politics thing but it's not that if I don't vote I'm not going to be a productive citizen. A lot of countries let you become a citizen without learning their language, most notably the US.
Being a part of society is a lot more than working and paying your taxes.
> A lot of countries let you become a citizen without learning their language, most notably the US.
An English test is required to become a naturalized US citizen. https://www.uscis.gov/citizenship/learn-about-citizenship/th...
Note: I'm only spreading rumors :)
What does that mean? Are you suggesting that countries should control where their citizens choose to work/live?
Why did you move there in the first place, raising a kid there, when just learning the language is apparently a hurdle too big to take?
This doesn't sound like a crazy requirement to me. The giving up other nationalities would be a deal breaker for me thought.
The US is "allowed" to offer whatever it wants for people to move there.
Recent European judgements seems to make it illegal to embed content from YouTube or Vimeo for example.
I don't see how dividing services up by region will help me anyway. I'd rather be able to choose from a few (I imagine there are more than a few at the moment) international Mailchimps than one in EU.
It’s similar to the UK’s pornography laws being more about surveillance and censorship rather than protecting children.
That's how the internet has been. That's how I feel about US tech giants getting all my data. They write their privacy policy, they dictate their terms, they follow US laws. I have absolutely no choice or voice or vote, unless one considers "yo dawg just build your own internet" a realistic choice.
I don't feel like the purpose is to drive out foreign competition. I feel like the purpose is to enforce privacy as a right, and I fully support it. I also fully support the right to transmit data across borders as long as the destination country also respects my privacy and rights instead of treating me as an alien and potential terrorist. Is that too much to ask for?
And in general, is following the rules of the country you offer a service in too much to ask for? Local laws apply to brick and mortar business; if Walmart wants to come to my neighborhood, sure go ahead, but please respect our laws. I don't see why internet companies should be above the law either.
GDPR is replacing rules dictated by US corporations with democratically established rules written by our representatives. It's unfortunate that there's now a clash between US laws and EU laws, but it's not the end of the world.
imo it's just a thinly veiled protectionist law that will fracture the internet all for the sake of propping up EU incumbents who can't innovate.
If free market were effective, we wouldn't have needed labour laws to keep people from dying in factories where they work 16 hours a day, we wouldn't need laws to make vehicles safe, we wouldn't be desperately looking for agreements to curb pollution and climate change, we wouldn't need laws to protect minorities against discrimination.. hell, I don't think we'd need laws at all because everyone would just rationally and effectively choose good actors & displace bad actors.
It's a nice fantasy, but it's not one we live in.
Even the US knows rules for markets - it’s never entirely free. European laws just set more rules and give the consumers more rights - something I consider useful where there’s a strong imbalance in knowledge and power between the consumers and the companies offering a service.
National regulation is a form of centralized economic planning. Is it always bad? No. Is it always good? No.
TikTok was nearly forced to sell parts of its operation so it could continue operating in the US, in India it's actually banned.
> DuckDuckGo's success is an example of that.
As good as DDG is, it's not that great of an example as all the background tech there still relies on Microsoft's Bing, which means there is very much a US-centric search engine monopoly in place.
> that will fracture the internet
Maybe the Internet needs fracturing, we've reached a point where a handful of US corporations control the vast majority of the web traffic [0], that kind of massive centralization is the absolute antithesis to what the web is supposed to be and presents a massive filter bubble in-itself.
[0] https://staltz.com/the-web-began-dying-in-2014-heres-how.htm...
Yes, that's a great example of protectionism that was reversed.
> As good as DDG is, it's not that great of an example as all the background tech there still relies on Microsoft's Bing, which means there is very much a US-centric search engine monopoly in place.
DDG is not the only privacy focused search service. There are others with their own homegrown search engines. I believe some of them are French. This also reflects consumer demand. DDG only able to evolve and grow based on how many people want to use the service.
The US could coordinate and work with the EU to try and craft laws that span both regions in a unified manner so that businesses can operate more freely but instead they're choosing to subsidize a protectionist agenda by levying a cost on the privacy information of its residents.
I love your wording. Regulation mixed with "operating more freely" is oxymoronic. The same can be said with your argument of "subsidizing a protectionist agenda" when you're referring to the lack of regulation and legislation.
> As a counter point - I think it's fair to view the extreme lack of consumer protection laws in the US as protectionism for domestic tech companies. T
The spat between US tech companies and France's ancient media companies is not new. It's very disingenuous to pretend that the purpose of these laws is just to protect consumers.
Regulation is a firm requirement to a free market, without regulation of any kind you will pretty quickly descend into authoritarianism as whoever has the biggest stick will just take everyone else's stick. While there definitely are dangers at the other end of the spectrum if you're fanatically at either end you've got to ignore a whole bunch of pretty well known issues.
> Regulation is a firm requirement to a free market, without regulation of any kind
I agree, but there are lines that when crossed either negates or greatly lessens the overall benefit for most people outside of vested interests.
> you will pretty quickly descend into authoritarianism
Moreover, historically speaking - centralized economic planning tends into devolve into tyranny vs systems with primarily free markets.
This is also much less about protecting consumers than it is about protecting old French incumbents who are unable to evolve.
Common regulation between jurisdictions allows businesses subjected to the regulatory oversight of multiple involve jurisdictions to operate more freely than if the jurisdictions did not coordinate and instead adopted regulations where it was impossible to comply with one without violating the other.
You shouldn't just pick one word from one part of a statement and a two-word phrase in another part and ignore the rest of the statement in order to create your own argument to respond to.
No, I’m pointing to the exact subject of discussion, the suggestion that the US and EU, who currently do regulate and do so independently, could coordinate regulation.
This isn't a case of doublespeak at all - it's just that the world isn't a simple place.
> regulations often help to make free markets more free.
No. They do not. That's nonsensical. The whole point of regulation is to exert control over something for better or for worse, depending on the situation. That's the exact opposite of freedom regardless of the consequences.
Your analogy is poor because it doesn't mirror the original quote. A better analogy that mirrored the original quote would be, "We need to murder people in order to save their lives." It makes about as much Orwellian sense as saying, "There's freedom in slavery."
I’m specifically addressing how the statement which branched this sub thread off was, itself, a non-sequitur to the statement it pretended to rebut.
There are many good arguments in favor of regulation, but that is not one of them, despite all the mental gymnastics being done to pretend that it’s a good argument.
...when convenient.
I have enough things to worry about, I don't want to consider 10 different cloud computing options, 10 different database options, 10 different analytics services. I want to just go with the big popular option.
Heck I'm willing to bet even if more options come up, the most popular option will be some aggregator site that tells you which one to use.
Could this not also be said about US regulations such as CLOUD act, Section 702 of the Foreign Intelligence Surveillance Act and Executive Order 12333.
I don't think it's accurate to solely blame the EU when this is in response to legislation that gives/gave the US access to all types of personal data on European citizens.
I would argue that the Americans getting better privacy protections and working with other countries instead of forcing American companies to behave illegally abroad would be a much better solution than the Europeans watering down their privacy laws.
American companies will set up independent shell companies or subsidiaries to serve European customers anyway. Microsoft and Amazon are never going to voluntary leave a market of 400M customers. Doing so would leave too much room for a competitor to grow and then threaten them. So if fragmenting the web means that Europeans get the same services as Americans, but with better privacy, then I am all for it.
Europeans are to blame for the flaws in the GDPR, not for doing their thing without the blessing of the Americans.
The logic is understandable. Surely, if you just get rid of the abusive American monopolies the home-grown companies will take their rightful places... right?
The only reason the privacy shield agreement was thrown out was due to lack of safe guards from US intelligence.
Even without the privacy shield, US companies would still be able to store EU data in a country with an adequacy decision if it wasn't for the CLOUD act. This seems more to do with US law wanting access to EU data.
The US does not have to give anything in return to get all the private data from EU they want.
The EU in return gets...nothing.
If you are a politician this is not a great position, you get no money, no jobs and no data.
If they equalize data access, "data sharing" (on an intelligence and on a commerical level) could be a valuable component of future negotiations.
The EU gets the services they use....
However from a political standpoint that's as good as nothing.
I’m Danish and as we’re a notorious Microsoft country I have the most experience with everything Azure, but the fact that Amazon was so quick to ensure that 100% of the workers who ever come near the services they sell within the EU are EU citizens is something that we still looks somewhat envious toward. It’s actually an area where Microsoft might eventually run into some trouble if they don’t work on their compliance but I can certainly understand how it’s hard when one of their key selling points to Enterprise is that we can call Redmund.
I don’t think the EU will get into much trouble over this, however, and I don’t think it will have too much of an impact on our tech industry. I do agree that it’s not likely to help European alternatives to Microsoft or Amazon, but that’s not exactly the point or the legalisation is it? It’s there to prevent EU citizens and our personal information from becoming the primary commodity that is sold between giant companies.
Advertisement companies like Google will no doubt struggle with this going forward, but is that really a loss for anyone?
Uh not sure what you're referring to but that's not true. The only airgapped region w/ enforced citizenship was for US citizens in GovCloud.
Building satisfactory alternatives to Office, Workspaces etc. isn't a monumental task by any stretch. With the sudden demand that you predict, they'll spring up like weeds.
This might be ham-fisted and crude, but in the end I see a lot of positives.
Developing the product itself isn't the reason.
Also, the competing EU-based service might be strong competitors to the ones in the U.S., among people like me who are privacy conscious. I don't use Google services, but I'd be happy to consider using GDPR-compliant services based in Europe.
Libre office is a third option, but does it have much usage? Why or why not?
Could you sustain a development team capable of creating this with a limited market and revenue stream?
Market wouldn't be limited and potential revenue streams would be huge. So yeah. Just as a reminder, this is still assuming that there is a significant window where the big options aren't available for Europeans.
This is how promising companies are swallowed by the market leaders.
Elsewhere "fragmentation" is called diversity and competition. It's sad that it has to come about due to regulation, but it's a good outcome nonetheless.
The familiarity and precedence of current offerings becomes a kind of Stockholm syndrome for people. More options mean more chance of valuable improvements, and geographical diversity means different mentalities and points of view, instead of more "me too" options.
I'm so looking forward to that.
Also, there's no reason that collaboration tools must be hosted on a US cloud. Especially Microsoft traditionally provided tools for their customers to host their own infrastructure -- it's only a recent phenomenon that everything is hosted by the vendor themselves.
It is true that both the EU and China are swiftly heading away from this unprecedented era of technology companies being able to act as they please abroad without impunity. It is an era that the US, which benefits from this arrangement greatly, understandably does not want to leave.
But what matters is why they are doing this, not that they are doing it. And in that regard it is much harder to find similarities.
No need to go cloud everything. I think you can even buy the whole azure pack to run on-site.
We can create a middle ground. When ever information about a EU citizen that get transferred to the US, a similar information about a US citizen get transferred to the EU as hostage in case there is a data violation. A list of IP-addresses accessing usa.gov in return for a list of IP-addresses that accessed europa.eu. Surely a deal can be made that give both sides equal power.
Privacy abuse on such a massive scale, never before seen in human history, requires action.
And it does not matter how normalised this has become for the people in the valley of the clueless.
Popular video conferencing solutions weren't allowed due to privacy issues. The official "Lernraum" platform that have been used for this did not work most of the time.
I understand where these laws come from, but it's sad that there often is no European alternative
The EU can build it itself when the US player are not able to not send data to their US data centres.
I think you are overestimating the problem. Before Facebook decided that it wanted the European market we had hundreds of similar services. We will have local replacements the moment these US companies with their near unlimited war chests finally fuck off and give European companies room to breathe again.
That's not exactly a great argument here, given that this French court has objectively made the right legal decision here in terms of EU privacy law, and the rights of their citizens.
Will this enable them to comply with the requirements?
I have first hand experience of this, migrating between their global PaaS and the contained German one. The bulkheads are quite air-tight (much to my personal detriment).
They're working on it, but still not everything is entirely regional.
But, companies like AWS claim that they voluntarily bind them selves to to provide much stricter privacy safeguards than the US law requires[0].
[0] https://aws.amazon.com/blogs/security/aws-and-eu-data-transf...
For quite a lot of business data, the "do not export data out of region" thing is nothing new. Which is why it is not actually unusual to be able to select where the servers are located.
That being said, if this made Microsoft Teams impossible to use, it would made a lot of us happy. That thing is crap.
It is also silly to tolerate techs incessant fuckery.
If these companies end up banned in Europe, that's not really a problem from Europe's PoV. Europe may end up deciding that US companies not coming is a problem in itself, but that is already the case imo.
Honestly, if this policy is actually enforced, it's very hard to imagine how the landscape would shift. Maybe Europe would be brought to its heels, and be forced to remove the law. On the other hand, maybe the US would be forced to renounce their cloud act, which is a large part of Europe's privacy issues with US companies. A third path could be companies reverse-incorporating in some place that would let them keep in business.
It's a bit hard to predict honestly.
These regulations are the only way to dismantle US big tech monopolies. The US government won't do anything about it on its own accord because it's too profitable. Other countries need to neuter the influence of US big tech first. Then the US can police their own better to encourage intl competition if they want to.
The EU combined is the largest economic region in the world. With backdrop the other huge one China where doing business has become increasingly difficult and volatile.
Tech giants cannot afford to pull out of the EU. Call their bluff, they won't. They can't even if they wanted to, as shareholders will skin them alive.
It's not 2011 anymore. The GDP of the US has surpassed the GDP of the EU.
I'm teasing. I accept your new data, but I don't think it fundamentally changes my point.
I know you are just joking, but the sheer irony of a money printer joke in this context was just too much for me to not react :')
[1] https://blogs.microsoft.com/eupolicy/2021/12/16/eu-data-boun...
It is crazy to me so few realize it is really not much, if at all, harder to run a business without involving US surveillance capitalism corporations.
Tools like Nextcloud, Matrix, Jitsi, have turn-key SaaS providers or you can self-host them easily as well. Same for many many analytics solutions.
I honestly think every company would be better off having more sovereignty in their tech stacks and data, and it is much better for consumers who may not realize they are -also- sharing their data with third parties like Google who use it sell targeted behavior changes to the highest bidder.
PaaS and IaaS providers all have a presence in the EU or is that still not good enough to pass the regulation that's in place?
SaaS I get it, they'd have to create a presence in the EU but I don't think that's a bad thing. They will, at least the big ones you mentioned. And if that's a problem for smaller SaaS providers then the market will have a solution for that emerge over time.
Wait until you see the result of the green revolution: you'll pay your energy 3 times more than now.
We'll need decades to recover (if we recover) from this ideological move from people that lives in la la land and have no idea of the consequences of their acts.
It already has started with natural gas prices skyrocketing. The Russians are holding us by the balls and our politicians are spitting at their faces...
You can't just delete nuclear, coal and natural gas power plants and think the invisible hand will provide. There is no secret plan behind: we're gonna crash then our politicians will blame the Russians and / or COVID but certainly not their incompetence.
Don't get me wrong, I don't want to live in a polluted world more than anybody else, but I also want to take a hot shower daily without it being a luxury expense. We needed to think the transition and do it progressively before. Too late.
I wish!
I still don't think laws against specific software is helpful though.
And then they will not be able to serve the european market, nor profit off the european economy. Good luck competing with each other for that US market.
And even then it seems risky the EU will deem the business model entirely in violation of privacy laws. It's very chilling
When the EU finally completes their utopian/dystopian ideas of privacy from foreign Internet services, the great firewall of Europe, perhaps then EU regulators will look inward and do the same things?
But for now it all has the appearance of disfavoring International Internet services, as if to encourage regional tech companies to advance.
Which seems reasonable, Europe seems to have lost most of it's Tech companies, and that's a problem that needs to be fixed. It's just weird to go about the problem by claiming International companies are in violation.
It's not Europe who blocks anybody, but plenty of US websites just blanket-block EU visitors because they can't be arsed to create a GDPR compliant website.
Which, as a European, in practice feels like running into a great American firewall.
For that simple reason the EU has to step in. There is no other way.
This is what you are wrong about. It would be true if you were from a small country like Sri Lanka or similar but for EU many European companies will smell an opportunity to fill the void.
I support their work to protect the privacy of EU citizens. But I'm also aware that their goal is to replace Microsoft, Google, Facebook etc. with state-owned European enterprises.
European state enterprises can be surprisingly efficient. However keep the Germans out of it. German government IT is still in the Middle Ages. Let countries like Denmark and Estonia build the future of European IT.
It will take forever to build up a similar ecosystem in Europe and I think most successful European entrepreneurs will just end up starting companies in the US instead.
There must be some reasonable middle ground before we fragment and destroy the entire Internet. Why not start by making a general exception for temporary storage of less sensitive data like IP-addresses for efficiently and cost effectively delivering a web service.
If there is one thing they could start looking in to it would be handling of personal information by governmental organisations. I work a little bit with a few municipalities, and the number of documents with deeply personal information that are just emailed around over unencrypted email is shocking.