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Re: [Sks-devel] Implications of GDPR

From: Klaus-Uwe Mitterer
Subject: Re: [Sks-devel] Implications of GDPR
Date: Sun, 29 Apr 2018 14:22:10 +0200
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Hi Moritz,

My understanding is that the section you quoted on the "right to be forgotten" refers to the controller's (i.e. your) obligation to inform _other_ controllers processing the data (in this case: other keyserver operators who, through gossip, have a "copy or replication" of the personal data) about the data subject's request for deletion. "Technical measures" in this context would, for instance, be a way to automatically propagate the deletion to other servers; as this is not possible, you only have to take "reasonable steps" to inform others, like sending an email to your peers. If somebody wants you to delete their data, you will definitely have to delete it, regardless of how difficult this is to achieve with SKS.

A whole different issue is how you would get a data subject's permission to process their data in the first place, and how you would notify them about the fact that you are processing their data, both of which are required by the GDPR.



On 2018-04-29 13:02, Moritz Wirth wrote:
Hi Fabian,

first of all, I am not a lawyer so you should not rely on my response as
it may be wrong :)

- The GDPR applies to all persons and companies who are located in the
EU or offering goods, services or who monitor the behavior of EU data
subjects - this means that all keyservers are affected regardless where
they are physically located. (

- Personal Data includes Names, Photos, social posts, IP-Addresses.. (so
it seems that everything that can be connected to a person is included

- The Right to be forgotten: People have the right to get their data
deleted if it is no longer necessary in relation to the purpose they
were collected. I think this means that if someone wants to have their
data deleted, you have to delete it - given the fact above that some
keys include personal name or even photos, you would be required to
delete them (even if you are in the USA). However, I am not sure - the
text says "the controller, taking account of available technology and
the cost of implementation, shall take reasonable steps, including
technical measures, to inform controllers which are processing the
personal data that the data subject has requested the erasure by such
controllers of any links to, or copy or replication of, those personal
data." <-- Given the fact that it is not possible to delete data from a
keyserver, I am not sure how this would be handled. (Same applies to for
reasons of public interest in the area of public health in accordance
with points (h) and (i) of Article 9(2) as well as Article 9(3) but I
didnt check on that). (

- I heard that you must sign (physical) contracts with data processing
companies (this may also include Google and Google Analytics, I am not
sure about Google Fonts etc but since Google gets your IP...) if you
share the data of your user with them (e.g using GA on your site).
("Controller will need to have in place an appropriate contract with any
other Controller that it jointly shares data with if that Controller
particularly is outside the EU."). Should not really matter (except for
Google Fonts) - at the end the use of Tracking services is up to the
keyserver admin itself

The first thing I would do is to include a checkbox in the webtemplate
that every person who queries or uploads a key via the webinterface
agrees to your data policy - in the data policy you should explain what
happens when a key is uploaded, that it is distributed to other
keyservers, (IPs are collected whatever you do) and that it is not
possible to delete keys once they are uploaded.

If someone has more information on this or something to correct feel
free to do so :)

Best regards,


Am 29.04.18 um 12:24 schrieb Fabian A. Santiago:

As I understand it, GDPR concerns all EU citizen users of a site, regardless of where the site is hosted. How does this affect keyservers? I've seen at least one server going offline due to it. Should I be concerned as an American keyserver host? 

Fabian A. Santiago


0x643082042dc83e6d94b86c405e3daa18a1c22d8f (current key)
 0x3c3fa072accb7ac5db0f723455502b0eeb9070fc (to be retired / revoked)

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