IETF: GDPR compliance means caring about what's in your logfiles

Don't log too much, nor keep the files for too long, to stay on right side of Euro privacy rules

Sysadmins: while you're busy getting ready for the GDPR-regulated world, don't forget what your servers are storing in their logfiles.

That advice comes courtesy of a draft mulled by the Internet Engineering Task Force's Internet Area Working Group (IETF's INTAREA).

The document, here, offered a handy checklist as a set of updates to RFC6302, “Logging Recommendations for Internet-Facing Servers.”

As the draft noted: “In the past couple of years, new data privacy regulations with wide geographical scope are entering into effect with big effects for technology companies and technology consumers around the world. The combination of these changes, in IETF procedure and regulatory requirements, have caused some previously established best practices to become poor practices.”

The IETF suggests sysadmins adopt a data minimisation approach to configuring their server logs:

  • Full IP addresses should only be stored for as long as needed to provide a service;
  • Logs should only include the first two octets of IPv4 addresses, or first three octets of IPv6 addresses;
  • Inbound IP address logs shouldn't last longer than three days;
  • Unnecessary identifiers should not be logged – these include source port number, timestamps, transport protocol numbers, and destination port numbers; and
  • Logs should be protected against unauthorised access.

Why three days, by the way? Because that lets logging cover a weekend before it's flushed.

The draft also suggested that if service providers plan to, or think they need to, store more than the data listed, they would probably need users' permission. The document added that since users aren't under any particular obligation to help “improve your service”, permission should be sought even to store data for that process.

The advice stretches beyond the purely European providers, since anybody offering services to anyone in the EU needs to comply with GDPR. Vulture South also notes that legally-mandated logging, such as to comply with local telecommunications data retention laws, isn't covered by the draft.

Cookie popups here to stay, for now

On other matters GDPR, privacy consultant Lukasz Olejnik took a look at the vexed question of “cookie consent”, that annoying popup that's been the auto-nag environment for years.

Looking at the GDPR Working Party 29 final guidance, Olejnik said, the “implied consent” Website owners have assumed existed once people clicked “I Agree” to cookies probably no longer applies.

Not only that, but an administrative slip-up probably made things worse. The EU intended to publish an updated ePrivacy Regulation, simultaneously with the commencement of GDPR, to relax the “cookie popup” requirements.

That didn't happen, Olejnik wrote, and as a result, “data privacy rules on the web will be governed by the old ePrivacy Directive and GDPR at the same time, with GDPR having the precedence. GDPR is consent specific, so it is not surprising that Working Party 29 says that there is no way “implied consent” can get you compliant for sure.”

Until Europe finalises its ePrivacy Directive, site owners will need to think about the privacy design of Websites to maintain compliance, he wrote. ®

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