If website logfiles are to be purged after 7 or 14 days, are you allowed to 
keep website analytics as long as they are anonymous, i.e. divorced from 
visitor identification like IP addresses?  I'm talking about counts of 
pageviews and unique visitors, top referrers and entry pages, browsers, etc.

(Still not sure why an IP address is considered personal or private 
information.)

 
-----Original Message-----
From: Blueonyx <blueonyx-boun...@mail.blueonyx.it> On Behalf Of Michael Stauber
Sent: Thursday, May 24, 2018 6:35 PM
To: BlueOnyx General Mailing List <blueonyx@mail.blueonyx.it>
Subject: [BlueOnyx:22107] Attn. German BlueOnyx users: DSGVO update (again!)

Hi all,

First of all I'd like to thank Dirk Estenfeld to bring this to my attention.

On 25th May 2018 the DSGVO (GDPR) comes into effect. To that end we already 
published updates for BlueOnyx which allow you to configure data retention and 
expiry.

German BlueOnyx operators need to pay special attention, though:
=================================================================

By default BlueOnyx keeps 14 days of logfiles in /var/log/.

And we know that German lawmakers are incompetent fuckwits who refrain from 
putting exact specifications into law. Instead the applicability and specifics 
of each law need to be contested in court.

The DSGVO does not expressly state how long server logfiles *may* be retained. 
The *consensus* on that stems from exemplary judicial court cases.

The case everyone seems to settle on (BGH · Urteil vom 3. Juli 2014 · Az. III 
ZR 391/13 - see: https://openjur.de/u/704445.html) established that in the 
circumstances given in *this* court case 7 days of logfile retention was fine.

It doesn't make 7 days the law, as there might be legitimate exceptions where 
longer logfile retention *may* have a legally acceptable basis like mentioned 
in § 100 Abs. 1 TKG. But it would require taking such a case to court (again) 
to test it for legal conformity. And even then it would just apply to these 
exact circumstances. Great, isn't it?

Long story short:
==================

Another set of updates has been published for BlueOnyx 5207R, 5208R and 5209R. 
With that installed you can specify how long your server logfiles are kept and 
can choose a different period than the standard 14 days.

See: "System Settings" / "Data Retention" and then "Server Logfile Retention".

It's now possible to specify 1-90 days of logfile retention with 14 days 
remaining the standard value.

German BlueOnyx operators are encouraged and advised to configure 7 days 
logfile retention unless their legal counsel has a better idea than that.

--
With best regards

Michael Stauber
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