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RE: GDPR Issues

 
From: "Doug Levey douglevey@PROTECTED [Dada Mail Developers]" <dadadev@PROTECTED>
Subject: RE: GDPR Issues
In-Reply-To: (no subject)
Date: May 10th 2018

From:

Hi Justin,

All no problem - to be clear, my points were made from the perspective not of underestimating but of prioritising.

There are lots of people running around making a lot of money from GDPR over here at present. A large amount of the panic in the UK originates from the fact that the mass focus on Brexit completely over shadowed GDPR and the Information Commissioner (the UK regulator) had originally been criticised for being well behind the game for published information and advice. About 12 months behind.

So the urgency has largely been created by many large companies fearfully trying catch up from a position of not knowing how much of a problem they have. I have clients who run straight selling companies right through to traditional craftsmen who have held personal data and keys to historic buildings for over 75 years! As a side issue I also have extremely deep experience in the WEEE and RoHS Directives which, after a ten year campaign, myself and colleagues achieved amendments being written into the EU Directives.

Anyway, my point is only that things will shake down after 25th May - here in the UK the ICO has already indicated they intend to give much more time for charities to get their houses in order. I am totally aware of the likely amount of effort involved and I am guessing that your preference is to do things just the once 😊

So ... in the spirit of that, I also suggest your planning includes the ePR or Electronic Privacy Regulations which were due to take effect also on 25th May but have been temporarily delayed. The ePR has been dubbed 'the cookie law' but covers more than that and is intended to work in parallel with GDPR dealing mainly with the communication of personal data rather than the what, how and why of GDPR.

It would be a shame to modify Dada Mail for GDPR and then need to further adjust for ePR considerations. Equally I would be happy for you to take a little longer than 25th May to get things right and allow you to keep your sanity rather than go hell for leather in the next two weeks!

All best,

Doug

-----Original Message-----
From: dadadev@PROTECTED <dadadev@PROTECTED> Sent: 09 May 2018 23:10
To: Dada Mail Developers Subscriber <douglevey@PROTECTED> Subject: Re: [dadadev] GDPR Issues

From: justin@PROTECTED

On May 8, 2018, at 3:00 AM, Doug Levey douglevey@PROTECTED [Dada Mail Developers] <dadadev@PROTECTED> wrote:

> From: douglevey@PROTECTED
>
> Hi Justin from GDPR land!
>
> I have been doing a mass of stuff with GDPR and I would say that it does need taking seriously, but on the other hand I would encourage you to make any changes from the perspective that requirements need to be highlighted to the list owner/maker when setting up.

Doug, these are all great points (Mary's yours as well).

The breadth of these changes cannot be underestimated though. We're looking at a huge project. I'm looking right now at what I can deliver well before the 25th, and then go from there. A fundraising effort may be something that needs to be done aprés the 25th to to: (1. help the developer survive such an onslaught of development time (2. give a realistic pulse on if this app can battle it's way to the other side of GDPR. If there's not enough user interest, should I be spending my time on this, or is it time to (forcefully) move on?

I've read so many opinions on what GDPR really means for mailing lists, and no two opinions seem to line up perfectly. My thought on this is to make Dada Mail into something that can be used in a variety of situations, with the list owner (or at least the site owner) having final say on how they'd go about things. Some cases I have are still people who have private lists, outside of the EU (and EU users). I can't very well drop the features that make those sorts of lists feasible. What I can do certainly is make it easier to comply with GDPR - even be able to run a list in GDPR-mode, making some features hard to use or completely disabled. I'm of course a proponent of privacy issues.

There's lots of points I'd like to make on your reply, Doug, but I better get on with it. Again, I appreciate your input.

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