Counsel @shiftechnology. Keen interest in all things privacy, data, urban, global, empowering, liberating. American in Paris. Personal account, personal views.

Paris, France
Joined July 2017
My life, in a tweet, captured by The Onion.
Open-Minded Man Grimly Realizes How Much Life He's Wasted Listening To Bullshit trib.al/Ev2ls2e
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ngl I'd ban cars, you're welcome
Rowenna’s law would be a ban on junk leaflets
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tfw when the Pope and I are on the same side on geopolitics, racial justice, UBI, debt forgiveness, and ethical tech
Replying to @kayaoakes
Here's the full text of the pope's speech. Oh yeah he's also a UBI guy. vatican.va/content/francesco…
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Another day, another geolocation/IP-based website access block by a US regulator. (oig.hhs.gov)
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In the regulatory space, the highest common denominator is often the one that drives results.
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Revisiting this in light of today's OVH outage, relevant guidance from the CNIL on notification for availability incidents: cnil.fr/fr/incendie-ovh-faut… An additional perspective on the recent conversation with @PrivaCat @PrivacyMatters @montezumachavez @AlbusAlba and others.
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Clearest example I've ever seen. Ban cars.
🚲🚲🚲🚲🚲🚲🚲🚲🚲🚲🚲🚲🚲 Paint is not infrastructure 👇👇 HT @AlTi5
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I want to latch onto this for a sec, because it's really been getting on my nerves lately. There seems to be this sort of dithering affect in a lot of GDPR guidance that never actually...guides...anyone about anything. Too much GDPR guidance sounds like snotty academic pedantry.
This goes back to the comment @PrivaCat made about technical folks in the room - this sort of vague standard winding through reams of subregulatory guidance is cute but it's another example of lawmakers basically telling us they can't be bothered and we should go figure it out.
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Effective regulatory guidance has to include real world examples and measurable standards. Some GDPR guidance is quite good on this! But a lot of the rest of it is just taking two sentences from the reg and word-salading it with all sorts of ostentatious "thoughtfulness".
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(I should note that my undergraduate degrees are in philosophy and psychology. I know a thing or two about ostentatious thoughtfulness.)
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What I think GDPR-world sorely needs is a lot less "here's what was meant by [clause]" and a lot more "here's what [clause] requires you to do if you're doing [x activity]". Apply the reg to factual situations and give some parameters for what 'good enough' looks like.
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I totally get that regulators don't want to get too deeply into facts, for two main reasons: 1) there are too many varieties under a *general* data protection regulation, and 2) a rule for one situation still has to align with the underlying principle for all.
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But let's be real, we could probably come up with a list of 25 or so *achingly* common fact patterns, and it would be useful for the regulatory guidance to walk through these situations and map out what GDPR best practice looks like. We can iterate/extrapolate from there.
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(Yeah, I know that's what consultants and advisors are for. I'd rather save that spend for when it matters, not for building/refining basic processes. If I'm thumbing through a dozen treatises on the secret meaning of a phrase to make basic decisions, the guidance has failed.)
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I should at this point give a shout-out to CNIL for their very clear cookie ("traceur") guidance. Do more of this, y'all.
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"We verified it was you for purposes of responding to a SAR but not for purposes of addressing your racial discrimination complaint" gets a whole-ass yikes from me
Replying to @WorkerInfoX
Which raises the question that if Pa was sent his images, was this because the support team could confirm that the photos were of him?
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🤔
Le bruit est responsable de 4 millions de victimes de perturbation du sommeil, d’1,4 million d’obèses, de 50.000 diabétiques, de 630 000 malades cardiovasculaires, de 730.000 anxiodépressifs, et de plus d’1 million de jeunes en difficulté d’apprentissage reporterre.net/Le-bruit-detr…
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