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Comment by smsm42 | Hacker News Reader

It creates an obligation to businesses selling user data, or ones with revenues over 25 millions. It's not hard to find either: https://oag.ca.gov/privacy/ccpa

The CCPA applies to for-profit businesses that do business in California and meet any of the following:

Have a gross annual revenue of over $25 million; Buy, receive, or sell the personal information of 50,000 or more California residents, households, or devices; or Derive 50% or more of their annual revenue from selling California residents’ personal information.

It's not a very hard decision to make, the text is pretty clear. Especially if literally the fifth word of it - "for profit" - makes the further reading unnecessary.

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I'm reading that and I can already see things that require me to think hard about whether it might apply.

> any of the following

> Buy, receive, or sell the personal information of 50,000 or more California residents,

"receive" and "50,000" seem like a low bar if the definition of "personal" includes anything caught in typical web logging.

You see? It's not clear cut from reading the thing you just said was very clear and it's hard to be 100% sure it doesn't apply.

"For profit" and "business" and similarly wide nets. Business can include individual sole traders and "profit" could be "accepting donations" or "running AdWords"

As the author of that article, I bet I meet that bar as soon as one of my posts gets on the front page of Hacker News, very easily if I post multiple articles which ended up getting popular like I have this month.

Why are you collecting personal information (IPs) of your readers though?

Really I have the nginx logs going to the disk so that I can have prometheus-nginx scrape them for referer patterns (it getting above a certain threshold for a given referer is how I know when my article got posted somewhere), status code rates and overall to make sure that the core functions of the site (such as the RSS feed) are working like I expect. I could probably change it to write the logs to a unix fifo instead of a unix file, but I actually do end up going back to look at the logs for things like people attempting to exploit my code so I can harden my site appropriately.

Thanks! That's an informative reply.

I was wondering whether not logging could be an option. That's now quite clear.

I just checked the logs and did some reverse IP lookups at random and it turns out nearly all the IP addresses I have are cloudflare IPs. So I don't even have IP addresses logged the way I thought I did! Yay me!

Not OP, but IPs are not always considered personal information. If you never establish the identity of the consumer directly, its not clear that the effort required to convert that address to an identity meets the bar of 'reasonably capable'.

The point of my original comment was that there is gray area here and people dismissing it outright as obviously bogus are not thinking very critically about it. I think this is a good example of that.

It's kind of hard not to log IPs when running a service over the internet. You kind of have to have their IP address in order to know where to send the info they want.

Further, logging an IP address has also been necessary for security--to detect DoS and DDoS attacks, for instance, as both involve many repeated connections from the same IP (though you can offload that to a service now).

Why it is hard? The servers need to know the IP address, for sure, but they do not need to permanently record it. In fact, un-aggregated IP is probably not that useful for statistics either, I can be aggregated e.g. daily and then discarded.

You seem to be confusing temporarily holding information in the database (no matter whether in-memory or on persistent media) for operational purposes (be it networking or threat detection) and permanent storage of the same information way beyond the time it ceased to be useful for the purposes above.

As I understand it, from a legal standpoint, storing it for operational purposes is equivalent to storing it for any other purpose.

Also, even if you only store the information for 24 hours--how many users are on Hackernews in a given hour? How many of them click through the top links? Certainly enough that some sites have crashed under the load, which makes me think that the number is higher than 50K. Congrats, you're now storing 50K IPs, despite having an automated system to delete them in a day.

(I don't even wanna think about the headache it'd cause if you got dragged to court over this. I don't know how many judges will understand that you delete the list every 24 hours to avoid being liable for storing it, not to get rid of evidence.)

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