
Google plans to move UK users' accounts outside EU jurisdiction - nsdfg
https://www.reuters.com/article/idUSKBN20E08W
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jtylr
Previously posted and discussed here:
[https://news.ycombinator.com/item?id=22370405](https://news.ycombinator.com/item?id=22370405)

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three_seagrass
Duplicate:
[https://news.ycombinator.com/item?id=22370405](https://news.ycombinator.com/item?id=22370405)

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bananamerica
I’m sorry, am I on Stack Exchange?

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dang
On Hacker News, we're pretty careful about dupes, but for different reasons
and in a different way than on SE. Here the issue is that frontpage space is
the scarcest resource that HN has (only 30 slots at a time). Since the site
exists for intellectual curiosity, and curiosity withers under repetition,
it's important not to have those slots taken up by stories that have had a
significant recent discussion. (For example, the OP had a major thread
yesterday.)

Reposts are allowed in the other cases. That is, if a story hasn't had
significant attention yet, we don't treat a repost as a dupe. Similarly, if it
has had a significant discussion but not recently, it's ok to resubmit it.
That's because once enough time has gone by, the topic can gratify curiosity
again. The cutoff is a year or so. This is in the FAQ:
[https://news.ycombinator.com/newsfaq.html](https://news.ycombinator.com/newsfaq.html).

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bananamerica
It's okay to point out duplicates, it's just odd to see it done in such a
spartan manner over here.

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ckastner
The optics of this might look bad, but I cannot really fault Google for this
move (and I frequently fault Google).

They're facing a dilemma of regulatory uncertainty, and this move resolves
this dilemma for them (at least, they seem to believe that).

Anyone who has ever dealt with powerful regulatory agencies will probably
agree that this _resolution_ is the right move for the company, a move
important enough that eating some bad PR is probably totally worth it.

(The point about powerful regulatory agencies is not that it's hard to stay
compliant; it's that the costs, overhead, bureaucracy etc. of demonstrating
this compliance is immense, even if you are doing everything 100% right.)

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rconti
Pro-Brexiteers have often cited stronger bilateral ties, such as those with
the US, as an advantage of Brexit. And of course, post-Brexit, Britain will be
ever more reliant on the willingness of countries such as the US to cut deals
with them. As an independent negotiator in these new deals, Britain will have
less power to push back over silly things like data privacy; and as a member
of Five Eyes anyway, they're all too happy to have the US do their spying on
their behalf, just like the US likes Britain spying on US citizens to the US
Government's benefit.

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dilutedh2o
That sounds really interesting.

Would you mind sharing a resource to learn more about how the UK spies on US
citizens?

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andrewjrhill
[https://en.wikipedia.org/wiki/UKUSA_Agreement](https://en.wikipedia.org/wiki/UKUSA_Agreement)

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kelnage
Although if you look at the actual text on the UKUSA agreement document HW
80/2 [1], rather than the short synopsis from Wikipedia, it says very clearly
that the UKUSA agreement covers only sharing of "foreign communications" where
footnote 3 on page explicitly excludes communications of both the UK and the
USA.

1\.
[https://discovery.nationalarchives.gov.uk/details/r/C1153691...](https://discovery.nationalarchives.gov.uk/details/r/C11536912)

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rwmj
It is real. I just got an email about this from Google about my gmail account:

\- Your service provider and data controller is now Google LLC: Because the UK
is leaving the EU, we’ve updated our Terms so that a United States-based
company, Google LLC, is now your service provider instead of Google Ireland
Limited. Google LLC will also become the data controller responsible for your
information and complying with applicable privacy laws. We’re making similar
changes to the Terms of Service for YouTube, YouTube Paid Services and Google
Play. These changes to our Terms and privacy policy don’t affect your privacy
settings or the way that we treat your information (see the privacy policy
[link redacted] for details). As a reminder, you can always visit your Google
Account < [https://myaccount.google.com](https://myaccount.google.com) > to
review your privacy settings and manage how your data is used.

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nightcracker
> These changes to our Terms and privacy policy don’t affect your privacy
> settings or the way that we treat your information.

This is such a blatant lie what the hell. The only reason for this move is
specifically to treat your information in ways that are not legal now.

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dboreham
Not necessarily. They might treat information the same way but generate
different paperwork or have different levels of risk from frivolous lawsuits.

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projectramo
I imagine a future where the workers are on the Irish side of the border but
the servers are on the UK side of the border.

One still enjoys the tax advantages of the value being added on the Irish
side, but also the relatively lax data requirements on the British side.

I am not pro or con anything, just pointing out the arb.

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anticensor
Britain already adopted GDPR-based data protection law. If anything, Brexit
will tighten the situation by requiring the data of British to stay in
Britain.

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Zenst
That certainly is an outcome. Equally does add more credence to the Google
move as if the data was in the EU, then the potential to kick up a fuss and
roll out laws to insist it is in the UK would play out faster than say that
data in the USA.

Equally - I'd say costs may well play out more and what is the cost to host in
Ireland compared to hosting in the USA?

Even when we are talking pennies/cents in difference - at the scale of Google
- that soon adds up and if they can, they will.

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i287n
Does anyknow what happens if I move out of the UK to rEU? Will my account now
be considered to be an EU account or will it always be a UK one?

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bananamerica
Thanks, Brexit!

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s_dev
I would imagine N.Irish users might end up being covered by GDPR -- British
law also N.Irish people to declare themselves Irish under the GFA. N.Ireland
could well end up with a special status post-Brexit where it's both in and out
of the EU and in and out of the UK.

Given European data protection is much stronger than either British or
American DP it would make sense to group N.Irish people this way rather than
trying to deal with the exceptions.

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supergarfield
> British law also N.Irish people to declare themselves Irish under the GFA

This by itself doesn't mean anything for GDPR—GDPR applies to EU residents
(whether or not they are EU citizens), not EU citizens. Declaring yourself
Irish doesn't make you fall under GDPR protection if you live outside the EU.

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s_dev
GDPR applies to EU citizens globally. It's just not enforced globally. The
company will have to be large enough to have a presense (or future presense)
in the EU for there to be an tangible impact.

>Declaring yourself Irish doesn't make you fall under GDPR protection if you
live outside the EU.

I'm a DPO and this is absolutely incorrect.

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briandear
> GDPR applies to EU citizens globally. It's just not enforced globally.

Do American speed limits apply to American drivers in Europe? Or do the
European speed limits apply?

Essentially you are absolutely incorrect. The EU has no legal jurisdiction
outside of EU borders.

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icebraining
American tax laws (like the FACTA) do apply to Americans in Europe, for
example. A sovereign entity has jurisdiction over anything it wants. The
question is whether it can enforce it, but there are many tools for that, from
simple treaties to sanctions to full-blown military invasions.

In any case, parent is in fact incorrect since the GDPR claims no such
jurisdiction. It only applies to people in the EU, or to people whose personal
data is processed by EU companies.

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pmlnr
I don't completely understand what gives them the right to do so - legislation
are still in place, GDPR & the rest are included.

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rcMgD2BwE72F
GDPR only applies to EU residents, doesn't it?

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ollie87
UK citzens are still EU residents for now, the UK hasn't actually left yet.

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vechagup
The EU disagrees: [https://europa.eu/european-union/about-
eu/countries_en#28mem...](https://europa.eu/european-union/about-
eu/countries_en#28members).

The UK may still be following some of the EU's rules, but they have officially
left the union.

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CTn
Why Google plans to move UK users' accounts outside EU jurisdiction ?? <a
href="[https://www.currenttrendnews.com/2020/02/google-plans-to-
mov...](https://www.currenttrendnews.com/2020/02/google-plans-to-move-uk-
users-accounts.html">See) it.</a>

