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Ask HN: How are you implementing GDPR-compliant soft deletes?
67 points by xstartup 4 months ago | hide | past | web | favorite | 80 comments
The idea: Customer requests account or item deletion, you set it to "deleted" in DB without actually deleting it and it helps for documentation purpose should the dispute arise over some issue in future.



Soft deletes as you describe aren't allowed under GDPR.

But a possible solution may be to disassociate the data from the customer (as long as the data itself isn't considered 'personal data'). For example, if the reason the data falls under GDPR is because it is connected to the customers email address, you could clear the email address. But that wouldn't let you ever re-associate it. But you could maybe (but don't take my word for it) one way hash the email address (bcrpyt, etc.) and if a dispute arises in the future scan the hashes for a match of the person raising the disputes email address in order to re-associate the data.


My understanding, as someone implementing the GDPR-compliance for my company right now, is that if you could produce the same one-way hash a second time from the same input email address then the hash is still considered PI.


Fair point.

I can see the purpose of "right to be forgotten", but I think in some circumstances it is going to be abused. Any service that "bans" users for fraudulent/abusive activity and stores data about the banned user to prevent them from creating new accounts is going to have a problem. Banned user can just request to be forgotten and then create a new account. Unless there is some exception within GDPR that will support this use case.


This is probably covered by article 17, 3, e:

https://gdpr-info.eu/art-17-gdpr/

You're allowed to ignore deletion rules for the purposes of:

3 Paragraphs 1 and 2 [the rights to be forgotten] shall not apply to the extent that processing is necessary:

(e) for the establishment, exercise or defence of legal claims.


Yep, we've been through this discussion where I work just a few days ago and one way hashing even with salt is _not_ compliant as you can search for whatever you hashed and get a hit (SSNs, emails etc).


While GP stated soft-deletes aren't allowed, I figured I'd contribute to this thought exercise.

What about symmetric encrypting the field(s) and then giving the customer the key, and tell them to print it or store it safely, or else they won't be able to recover? And then don't store the key or write it to disk (remove it from memory)


Then you might as well scramble the data completely as the customer is not supposed to be able to recover the data after deletion.


We're going through a similar thought process now for a blockchain based data-store. If the data is symmetrically encrypted and the key is deleted.. does that count as hard deletion? The data is unrecoverable.


Do you know how you are supposed to handle disputes in the future? If I ask that all my information be deleted and I say n months later I was charged for something I never received, how does the company disprove that?


You are legally required to retain payment history anyways for many years. So that's out of the GDPR scope.


No, it is in scope. It is just that the laws are not always consistent. And that's a problem, because you can't be the arbiter of which law takes precedence.


GDPR explicitly lists processing that is necessarily to fulfill legal obligations by european or local law as permitted without further permission and as a reason to deny a deletion request, that covers at least a lot of it. (although you still have to report your use to the user and follow general guidelines on handling sensitive data of course)


So, it is in scope, since it is covered by the law, and then the law explicitly gives you permission to make an exception. But you'd better do all of the following:

- have a legally trained person review your eventual solution and your reasoning behind it

- document the exceptions, which laws and which datums it covers

- keep track of the law as it changes, especially with new bodies of law such as the GDPR you can expect updates to reflect the situation on the ground and in a way the GDPR itself is such a change.

- be prepared to review the situation/code if the law changes in the future

- be aware that 'data retention' laws are very different from one industry to another (for instance telecommunications is a totally different beast than e-commerce)


point b of Article 17(1) of GDPR specifically says: (...) and where there is no other legal ground for the processing;

Compliance with tax & financial regulations counts as a "legal ground". But that doesn't mean companies can retain all of the email history.


Exactly, you need to make this decision on a per-data item level. Financial transactions are at a different level than other customer interactions, and whatever the local laws for retention of accounting data state is what you will have to mark very explicitly as exempt.

This can get quite complicated, moreso if a company deals with both consumers and companies as customers.


This is the guidance we have been given as well.

It'll depend on the kind of data you're talking about. If you are obligated to keep that data for legal purposes then there's no working around that. But then make an effort to only keep exactly the data you need.

However in the context you're asking - absolutely do delete where possible. If not possible then pseudo-anonymization is a way of dealing with this.


Consult your Data Protection Officer first.

GDPR says you must delete information about the customer; but there are cases where you still might need to have that data available.

If your customer can interact with another one inside your app/platform, he/she can commit a crime, and you might be required by court (and by law) to disclose some information (even conversations! inside the platform).

Setting something to "deleted" might not be the best way to do the actual soft delete.

Sometimes you can "delete" that user moving it to a separate part of an LDAP branch (where nobody except someone with authority can access).

In other cases, you can add the "deleted" flag on the table. If so, MAKE SURE your app access the data from a view of the table where the 'deleted' users are not present. Even better: partition the underlying table based on the "deleted" field to physically separate active and deleted users.

But whatever you do, ask your Data Protection Officer first.


I'm going to go out on a limb here and guess that 99% of the companies out there affected by the GDPR and the OP in particular do not have a DPO (yet), and may not realize they need one, and even if they do know that then they likely won't be able to fill the seat either in time or with someone competent.

Every year we look at quite a few companies, this is the first year that I've spotted a DPO in the wild, and impressively, they even knew their stuff.


Not every company needs a DPO though, e.g. check here:

https://www.eugdpr.org/key-changes.html

Maybe his company doesn't need one. Of course, whether he has a DPO or not, still the question remains of how to "properly" delete the personal data.


It is quite well possible their company does not need a DPO. But given the nature of the question there is some evidence they do, besides that hiring a DPO is not something done in isolation but most likely as as the result of a GDPR impact study done in ... 2017 or so, which I'm going to again guess was not in the cards for many companies.

So, in summary: likely the vast majority of the companies affected is only now starting to wake up to the fact that they are affected, for quite a few of these companies the effects will be relatively benign unless their servers are compromised, for the more serious offender and the larger companies that have not yet started to address these issues it is likely too late to get anything done in time but since this goes for the vast majority of them they are simply playing a complicated game of Russian roulette with the oversight bodies and a couple of them will undoubtedly get lucky to great relief of the remainder.

Data protection authorities tend to be vastly understaffed, but this too will hopefully change in the future.


Yeah, I agree with everything you said.

It would be interesting to know whether the big companies have addressed (at least partially) their GDPR compliance. Maybe they do just "play Russian roulette" like you said, and hope for the best.. Of course, implementation guidelines are not yet fully defined (like WP29 opinions, some of them will change, even then, those opinions are not legally binding).


From what I've seen it strongly depends on the vertical but there are outliers both ways. With medical and fintech (banks, IPSPs, insurance) you can expect they are on average doing ok though there are some bad counterexamples. E-commerce is only just now starting to wake up and everybody else is going to be playing catch-up for the next couple of years.

Note that my sample is relatively small and mostly western European countries (nl, be, de, uk).


Is there anyone reading this whose company has a DPO already? Is it an internal or external person? How technical are they? I'm a developer and I have a law degree; would that put me in an advantageous position to become one? Is there a market for 'consulting DPO's', like companies hire accountants, if that's allowed? Or do the big consultancy firms have the GDPR market cornered already? I wouldn't want to go in a direction where I would become what today's 'security auditors' do - go through a checklist of mostly irrelevant topics, drum up a list of 'recommendations' that usually aren't relevant or misunderstanding the situation but nobody cares anyway because it's all just busywork to get 'certified' for this or that (or insurance requires it). But if it would be actually working with technical teams on questions like this, that would be interesting.


> Is there anyone reading this whose company has a DPO already?

I've seen one in all of 2017 (out of ~20 companies).

> Is it an internal or external person?

In that case it was internal

> How technical are they?

More legal than technical, but that's a very small sample.

> I'm a developer and I have a law degree; would that put me in an advantageous position to become one?

Yes. In fact that's probably one of the most lucrative combinations of fields.

> Is there a market for 'consulting DPO's', like companies hire accountants, if that's allowed?

YES! In fact if you are halfway decent this would be an extremely lucrative thing to do, but it probably will become less so over time as the knowledge gets diffused.


THe answer varies depending on the size of the company. However, I have seen many IT related professionals taking over the GDPR issues. In larger companies it is a more legal role. As to your career question: We are currently involved in many different and exciting project that push the boundaries of law and technology with respect to data protection. Currently, everyone is a GDPR consultant but quality and nature of the work differ substantially. For most part it is an exercise in producing documents and procedures to prove compliance. However, when it comes to implementing technical solutions you can really stand out. So if this is an area that you are interested in you should move fast. There is also a growing number of international opportunities as even non-EU companies require GDPR experts.


My employer (3000 employees, medical research) has an internal DPO. I only dealt with him once but was impressed with his technical as well as legal knowledge.


Yes, but it was a token gesture to DPA and in reality

1) It was not their main role

2) It was a token gesture, someone to address post too!

Every consulting firm I know is trying to sell GDPR services atm...


As far as I know the data must be properly deleted not just marked as deleted. Essentially you can zero out all fields which include personal information. Keeping the data as soft deleted you still risk it in case of a leak due to a hack.


> it helps for documentation purpose should the dispute arise over some issue in future.

If you are required to hold on to the data for legal purposes such as dispute settlement, there is no issue. The customer can request you delete such data but you have no obligation to do so. Issues arise when holding on to the data is no longer "necessary". At that point soft deletion is not enough and you must be able to remove personal data regarding that customer from your systems. Source: IP lawyer I talked with last week on this.

From what I can tell, one good way of going about this in case you really do not want to throw away data – such as when you're doing event journaling – would be to have all personal data encrypted. When the data reaches its expiration point or is requested for deletion, throw away the decryption key and all you're left with is is the metadata which you are allowed to hold on to for purposes of running your business.

EDIT: This concept is called 'cryptographic deletion'. Here's one whitepaper on the subject. http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.397....


Are you sure about throwing away encryption keys is sufficient to be GDPR complient? Does this comes from IP lawyer as well?


If the information no longer is possible to decrypt, it would no longer be considered personal data.


That's a good thing to point out, thanks. No, I'm afraid that bit is my own speculation.


I don't think "soft deletes" are actually allowed, are they?

https://gdpr-info.eu/art-17-gdpr/

> the controller shall have the obligation to erase personal data without undue delay


OK. Here goes... Advice...

Firstly, download the regulation itself. At the very least, read article 17. Article 17 concerns something called "The right to be forgotten". It is about 25 lines of legalese. Once you have read it, have a think about it. Then read it again and have a longer thing about its implications. Then, just to be sure you have not gone stark staring bonkers, read the rest. Carefully. Be under no illusion, the GDPR is a game changer in information management terms, let alone anything else.


Some comments on the legal aspect to deletion under the GDPR: 1. deletion can generally only be requested if the personal data is being processed under the individual´s consent. Thus, other personal data such as under legitimate interest or execution of a contract does not fall under it. 2. The rule on deleting the data is not absolute as data retention laws prevail over this rule. Thus, only if no data rentention law mandates the storing of the data (which is often the case for business communication) then you are obliged to delete the data or anonymize it. Hope this clarifies the non-technical aspect. Dominic Staiger https://www.raptorcompliance.com/en


Deletion of backup-data is also an interesting topic


The law itself was written by someone unaware of that. A lot of interpretations:

1. The most extreme, go back to all of your backups and delete them too.

2. You don't need to do anything, if you do not touch the backups and truly treat them for disaster recovery.

3. Your backups need to have reasonable retention (e.g. two year) and way to apply post requests after recovery.

4. A lot of in between.

5. My personal interpretation is that in first year of GDPR there will be so many companies that are not even trying to be compliant. Any companies showing any reasonable efforts will be just left alone and at worst heard some recommendations. Of course ad-tracking companies might get screwed, but their business model seems to be incompatible with GDPR.

Also right to erasure can be tricky (e.g. what if you keep records for support/warranty purpose). What you should do if someone exercise their right to be forgotten and than ask you for refund.


In what world is two years worth of backups required for reasonable retention? Either the backups are tiny or the company involved has got more money than sense. I'd see no reason, in any company, for backups to be held for longer than 6 months, and that would be an outside estimate (many companies could get away with only having a couple of months worth of backups).


In Norway you need to keep accounting data for ten years to be compliant with accounting laws so I you lose eight of them you would be in violation.

Edit: I see you mean retention, I guess if you discover after a year that your backup routine is malfunctioning and you need older backups but that is not that common I'd guess.


backups and archive are a different matter. Archives are meant to not be altered; ever (WORM disks[0]). Backups are made to be rewritten, ~~lost~~, or used for restoration.

[0] https://en.wikipedia.org/wiki/Write_once_read_many


If you have a lot of data, keeping backups for too long can be costly. But a lot of datasets are small (e.g. few GB) which makes keeping backups for really long time cheap enough.

If you're datastore is small (e.g. SQL table), but supersensitive (E.g. financial data), you may want to keep backups for really long and on medium that doesn't allow easy modifications (e.g. tapes or AWS Glacier).

I know some government (e.g. Poland social security) keep several backups in many locations for many years just as a redundancy.


Answer to point 5: On first glance I would agree with this view, however, there is the factor of market competition you must take into account. If a company only receives a small fine for non-compliance (or is not prosecuted) then its competitor can make the argument that this is anti-competitive conduct as the non-compliant company has saved money through its non-compliance and the fine does not stand in relation to the money saved. Through this argument the fines could increase significantly over a very short timeframe placing great pressure on companies to observe the GDPR. As the money goes to the data protection authorities their ability to prosecute will grow steadily.


I believe (not a lawyer, etc.) that you don't have to delete from existing backups as long as you have a process to immediately wipe the customer details again if that backup is restored (and before any other processing can happen.)

[edit to clarify that you wipe the customer details]


The way I'm handling it (probably non-compliant) is to store a list of the internal keys we use for people in a list as GDPR requests come in.

If I restore a backup it will go via this list and ensure that content in my backups which are keyed to deleted accounts are never restored.

In theory we have the data, but it's never reachable by internal systems. -- Anything else is essentially compromising the integrity of a backup.


Spot on. There are two major issues with the law as written, backups and conflicts with (possibly local) data retention laws, so right now the local data retention laws will likely take precedence and backups are not going to be in-scope until a lot of low hanging fruit has been plucked.


I won't touch my backups even if it means my company is killed by fines or I go to jail. Still worth it just to refuse submitting to this nonsense.


It's not nonsense, it just isn't quite put down in a way that is practical, on top of that it just makes demands and does not even begin to give guidance on how to comply with those demands which does not help for smaller companies.


We're building a consent framework API so our customers can consent for personal data use. Data is then cleaned and transformed (ETL) from personally identifiable to pseudo-anonymised. The data is also separated into two separate encrypted storages for anonymous and pseudo-anonymised data for generalisation and separation. Random (important) hashed identifiers are created and put into a metadata service which is used as a lookup-table. If right to be forgotten is invoked, the data is disassociated from the pseudo-anonymised and personally identifiable data thus making it anonymous.

Important is also how you handle data analytics and this is why we're deploying high restrictions on raw data. Analytics will only be able to be done through an analytics service which can give the employees access to only certain parts of the data which is approved for the use-case. We're using Apache Sentry for fine grained role based authorisation to data and metadata and a directory services for user auth.

Things we've learned:

* Minimise data usage

* Don't use personally identifiable data

* You will need to be able to prove consent when it comes to data usage and it cannot be consent by default, it has to be opt-in

* Log all data access so that use cases can be proved. This needs to be evaluated and audited

* Encrypt in transit and at rest

* Centralise mapping for all data


It may be that the future issues you envisage can still be met with anonymous data i.e. some overall audit of your service use. Anonymous data retains a small link to the original but is exempt from GDPR. One method is to generalise records in a database, for example, mask / remove direct identifiers like names, put ages in to age brackets and fuzz spatial data by x distance. So this can be used to deal with erasure subject access requests and sharing data in general. There's a lot of advice on this from the ICO - https://ico.org.uk/media/1061/anonymisation-code.pdf

Disclaimer: I'm a fan of anonymisation because I'm working on a project to bundle this in to a service - https://anon.ai - would be great to understand more about your use case.


All data under GDPR which also falls under another law can be stored, but NOT used for any other purpose than of the overlaying laws. So just because you have the information doesn’t mean you can use it. Having the same information, even “soft deleted” would violate GDPR since you are not allowed to store it like that. Having information grouped like that still implies information which will be under GDPR. Like if you store this information in the “customer” database that will imply that the customer was a customer at some time, and then illegal by GDPR. If you move this information to another database which stores “transactions” which you require to do by law that’s ok. But you are not allowed to query that information to answer the question, “who have been my customers”.


Hiya. If I may, a couple more things to add to considerations... Firstly while, rightly, you concentrate on the design impact of article 17. I guess most of you live and work in the US. What that almost certainly means, if you deliver SAAS, is that personal data is exported from the EU for use. You guys really need to understand GDPR Chap 5, articles 44 to 50 inclusive and get hold of something called "treaty 108" which is about the idea of "adequacy".

And secondly, I am going to ask someone I know who is a legal eagle to sign up to this site. She is very clever and knows this stuff backwards. She also has an aspiration to come and work in the US....


What if you outsource the PII? For example use a payment processor and only store their reference. You can always go back to transaction in the payment processor in case of disputes, but you don't store the personal information.


Then you will need a data processing agreement with that IPSP and they will need to prove to you that they are in compliance. The good news is that in that situation there is probably more knowledge and funding available to get things right (but it is obviously not a guarantee).


because the GDPR is a tad vague, given the interconnected world we live in nowadays (I am a brit living in a small (very) town called Tidworth which is a pin prick o the map) there is something called "Working Party 29" which is providing some fairly detailed and verbose refinements of definition of key phrases and terms. This is an attorneys bean feast as far as I am concerned because of the vagueness, if nothing else..


You can 'edit' your comments until they are one hour old, so you don't have to make many different top level comments.

Also, if you want to make a larger comment it is usually possible to resize the input field.


Your idea is not allowed under GDPR. You need to unassociate the account from the user.

That is: Remove all personal information - email, name, surname, etc..


But it is only part of a series of new bits of legislation that is being introduced in Europe related to computer security Some other acronyms "PECR" something all marketeers should have a look at as it governs things like email distribution


Another pattern you might consider is setting an expiry date on a database row. You only show values where the expiry date is null. Every night you have a cronjob or some other process that deletes all objects that have expired.


Not sure that would comply with the "without undue delay" requirement unless you always set the expiry date to be today and then you might as well just wipe them immediately.


You probably already add a "time created" column/field to each row/document (at least, I personally do this to all data I store in a database).

If you want to expire something, you can now easily calculate it and you can even easily change the timeout/lifespan without having to update the data in the database.


How would that help? Would you set time created to zero?


Rather than having an expire date, with a creation time you can e.g. delete everything older than 1 day, or what ever. I.e. you don't hard code the expire time in the data itself. If you want to change the timeout to 2 days it's a change in your delete logic, not your data.


This is how it was explained to me, and the approach we take. YMMV.

Understand what your lawful basis for storing and processing the data is, and that dictates how you need to handle it. Plenty of people throw around large fines and rights to be forgotten and make sweeping statements about "you can't keep X data/we can hash things!/delete all the things". You have a number of potential reasons for storing or processing data. Legal reasons, contractual reasons, consent based reasons - data subjects have different rights depending on the reason you're storing the data (there is a list of these reasons; see below.)

I may be keeping data because I have a contract with a client, and I require the data. An example of this would be an email address stored as a login. My legal basis for storing the information is contractual (I have a contract with my client). Does the data subject (in this case, the user who's email it is) have a right to erasure? No. Can I store the information in my Amazon RDS instance in Virginia? Yes. Provided I've explicitly stated it, and been transparent about how and where I'm storing and processing the data, and my client has agreed. Do I need to secure and look after the data? Yes. Obviously. Do I need to get to get consent from the user? No. That wasn't the legal basis for storing the information.

What about consent based stuff? I may have someone subscribe to my mailing list. I get their consent. Therefore, the legal basis for storing and processing is consent. That consent should be time limited, and I should be transparent about it. I need to give them the means to review, withdraw and act on their consent should they wish to.

What about keeping a record of a person you've deleted because they have requested it? You can store this. Lawful basis is that it's a legal requirement. If you go and use the data for any other purpose, it's not allowed - because that would require their consent.

If you want to understand lawful basis, this is a good overview - https://ico.org.uk/for-organisations/guide-to-the-general-da...

Trying to wade through one half of the GDPR and its requirements without understanding lawful basis leads to confusion, because you'll keep hitting cases that seem completely unreasonable (because they may not be required). Trying to paint the law vague and unreasonable defeats the point - it will become less vague over time. It makes privacy a first class citizen (something we sorely need), and will become more specific as it's tested in the courts, just like any other law in jurisdictions that value legal precedent.

Get to know it and work with it - this is not your mother's EU cookie law.


This is by far the best and most cogent answer in the entire comment section. Pity it's so far down the list.


What would be the sort of dispute you envisage?


Company gets hacked x time into the future, data that should not have been there hits the streets, E250K/violation?


Government: "You know that data you were required to delete when $(USER) requested to be forgotten? We require you to provide it in connection with our ongoing investigation of $(USER)."


Is this a real issue though? If I comply to regulations to remove data as required by law, I'd be surprised if a government body could require me to provide data I am supposed to have deleted.


This is a very real GDPR fear. Some of its mandates run counter to other local data retention mandates.

It’s not clear yet how that is going to shake out.


As HN'er detaro notes in this comment:

https://news.ycombinator.com/item?id=16366864

There are some provisions for those situations.

And on the subject of backups, those are typically exempt but there are some obvious problems there when you restore a backup at a later time.

To me the big ticket items in the GDPR are the notification duty and the data processing agreement 'chain' that gives some level of certainty that the companies you deal with are going to take this serious.

The implementation details and all the moving bits and pieces are most likely not going to be the parts where the real tests will be in the first year or two.


I agree with your assessment but the penalty part of GDPR is making lawyers more jumpy than any regulation I’ve seen.

I’m putting essentially everything in the we’ll see category.


I see that as good news :)

It looks like the GDPR at least gets people's attention.


About the GDPR, can anyone recommend a company in the UK they have dealt with, that brought them up to compliance?


If you aim to do this before May 15th you will find that anybody that is capable is fully booked for the remainder of 2018.


> you will find that anybody that is capable

Define capable. Look at this thread as an example. Many answers contradict each other. There are so many ways to interpret the guidelines, which in many cases have not been thought through.

I have engaged in discussions with 5 companies located in the UK. All gave differing answers on specific questions relating to data for marketing, finance, and fraud.


General compliance advice

1) Act in good faith. DPA fines seem to have been to people who had a blatant disregard for data protection and their customers, not those who tried hard but committed some technical breach.

2) Whenever new rules come out there is a long period of interpretation. Unless you are in a very high risk category I wouldn't 'throw the baby out with the bath-water' in the interim.

3) Documentation wins court cases.

4) Personally I was already trying not to have my data stolen, so I am not overly concerned by GDPR. I am updating some policies, employee handbooks and terms. I will watch how other companies deal with it before I act too rashly.


The most important bit that you can do that is actionable and that will not be open to interpretation is to have someone competent write a clause into employment contracts regarding data confidentiality, to put in place a protocol on how to deal with various levels of breaches and to review your sites privacy policy to ensure that it is still applicable (this is something you should be doing regularly anyway).

On the whole I think your approach is a very balanced and reasonable one, especially the 'act in good faith' bit. What surprises me is that plenty of companies explicitly do not act in good faith and try to interpret the directive creatively so that they can continue to do what they were already doing without modification. That's asking for trouble in my opinion, some companies in that bracket will find themselves in the un-enviable position of being used to educate the rest.

Especially in adtech and marketing there will be a lot of tension between business goals and the law as written and the finer you want to ride that line the more important it becomes to have competent guidance.


That was my point.

You need to know the law inside out to be able to tell someone exactly what to do in their situation. We - our little band of friends - have been reading up on this subject since the previous privacy law was enacted and all I can tell you is that it is much easier to spot things that are in conflict with the law(s) as written than to come up with a single workable solution that does not leave things open to interpretation.

Even so, these laws are good, they will force people to wake up to the underlying issues and to begin to think about their responsibilities when before the mantra seems to have been that any effort spent on privacy and security is better spent on growing the business because otherwise the other guy that doesn't care about those things will eat your lunch.


[flagged]


> When someone asks for recommendations. If you are able to help that person, then please do so.

No. Recommending commercial entities to others is not what HN is for.

If you want such a thing you are more than welcome to contact me or others out-of-band.

> It helps them and it may help others in the HN community.

Yes, or it may steer them in the wrong direction entirely.

I don't think this sort of advice is best dispensed through a public forum, reputations of companies are at stake and without enough context it is impossible to make a good advice to begin with.

It is closely related to people dispensing legal advice in forums, better yet if they're not lawyers. The line that comes to mind is 'advice is worth what you pay for it'.

> What you should not be doing, is your previous reply. In no way was it warranted, nor was it solicited.

That's your opinion, mine is a different one.

I get regularly asked to recommend services or companies (by those companies and by their prospective customers) and as a rule I will only do this if I familiar with both parties and consider them a good fit.

That's a thing borne from experience, which again you may disagree with but this has served me well over the years.

> I cannot believe some elements of HN behave in this manner.

And I can not believe that you feel that you are doing any better with this comment.


Ladies, gents... The kinds of things you are saying/asking about GDPR are the same kinds of things being asked on this side of the pond...




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