New UK data laws could be incompatible with GDPR in the EU
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Europe - with 300 million people - can set new standards that others have to implement. The UK, or what will be left of it, not so much.
But the really disturbing thing about the UK is that there are many people in power to whom human rights are less important than "souvereignty". UK experts have lamented for a long time the backwards looking whining and longing for the UK's past glory (ironically, the same backward orietation is what made Russia go to war - glorifying and trying to restore USSR times).
Perfidious Albion cannot be trusted when it comes to Northern Ireland, at least.
During the referendum, it was a different story. Just the EU that was the problem. Nobody is talking about leaving the single market, no sirree!
The main changes being proposed are to give the government of the day more power and less judicial oversight, not parliament. Most changes are about removing people's ability to take the government to court. So it is the government of the day that becomes more sovereign, not parliament.
The changes don't affect parliament at all.
UK parliament is and always was ultimately sovereign on these issues. That was already true, with or without the Human Rights Act, and even when the UK was in the EU. (Otherwise there would have been no need for the UK to create its own Human Rights Act.)
In fact it was the UK parliament that put this judicial oversight of government in place in the first place by passing the Human Rights Act. Fashions change, and the current lot in power want to take the oversight away again.
I don't recognise your characterisation, but that would be the ideal. That is not what is currently in process though.
>> The main changes being proposed are to give the government of the day more power and less judicial oversight,
Well, it gives the UK people more power. The elected government is a proxy for that.
>> UK parliament is and always was ultimately sovereign on these issues. That was already true, with or without the Human Rights Act, and even when the UK was in the EU. (Otherwise there would have been no need for the UK to create its own Human Rights Act.)
Yes, in as much as they decided, as sovereign, to give powers away. They are now as you say taking those powers back.
Oh I'm sorry, they're just replacing them with ones that can be enforced or ignored at will
Supporters of human rights may find comfort in the fact that the UK is actually bound to the ECHR by various international agreements, including the Good Friday Agreement. This severely limits politicians' ability to scrap its applicability altogether, despite their repeated promises to the contrary. This excellent blog post from June summarizes all this well: https://davidallengreen.com/2022/06/oh-no-not-again-the-stor... .
Most recently the UK government introduced a "Bill of Rights". Despite its name, it changed little with respect to the applicability of the ECHR, but it does make it harder (again) for litigants to rely on the Convention in practice.
(Note that the ECHR, both the court and the convention, are completely separate institutions from the EU.)
the European Convention on Human Rights was mostly drafted by a tory
the modern tory party's problem with the ECHR are its ability to create new law that is not subject to democratic oversight, namely around positive obligations
But Oxford is an anti-Brexit, pro-European place. The academics (there are a large number) and the locals both dislike Brexit and voted against it.
https://www.bbc.co.uk/news/uk-politics-eu-referendum-3661540...
It's surprising to many Brits how many of the leading lights of Brexit belonged to these groups as students.
You might not think this if you heard about all the privately-educated and often wealthy Conservative politicians who came through Oxford University.
So I just wanted to clear up any impression that either Oxford town or Oxford University are like that. They aren't, and most people there are aghast and sad at Brexit.
In contrast, Oxfordshire the region outside Oxford, is more pro-Brexit and much more pro-Conservative than Oxford University and Oxford town. It might have something to do with who owns land.
The same contrast shows up with regard to Green policies, voting Labour, and proportional representation. Oxford town and members of Oxford University (which is a large number) typically vote Green, Lib Dem or Labour, and the Conservatives do poorly. It's politically a progressive place with an international outlook, compared with the surrounding county and the rest of the country.
That hardline Conservatives are not well regarded by Oxford University members is shown by its governing body voting as a protest to refuse Margaret Thatcher an honorary degree when she was prime minister: https://www.theguardian.com/politics/2010/jan/30/thatcher-ho...
the EU's share of world GDP is in terminal decline (down from 30% in the 80s to about 15% today)
its ability to export its legislation will be gone by 2050 (if not sooner)
I am interested in your assertion about the actual numbers 1980s vs today. Can you provide a reference for that please? The direction of travel in those 40 years seems plausible to me. After all, China has definitely become a much bigger slice of the world's productivity pie than it was then so others must have a smaller ratio than they did. But the absolute numbers are kinda interesting.
it is simply a.completely non sensical post.
in the 80s Europe was formed by just 12 countries, EU did not even exist, euro did not exist, Germany was two countries, there was a wall in Berlin dividing the city in east and west Berlin, USSR was a global power and we did not calculate in the global GDP more than half of the World.
That's why the downvotes.
I don't think that will be the case. Most of the decline is not absolute but relative, due to China growing. But they're finding themselves seeing reduced growth now too.
US GDP was %40 of the entire worlds economy, it dropped to %30 by the 1985 and today its below %24.
That's simply a function of population and development and in world where every nation reaches property it would be proportional to the population.
If China and India happens to transform itself into prosperous countries, US and EU and everybody else will follow and for the better because this is not going to happen in their current state of affairs.
The UK is neither a small country or a small market. While not as big as the EU, the UK is no where near as irrelevant as you're making out. I could also make the argument that many US sites refuse to comply with EU GDPR regulation so, no, others clearly don't "have to implement" EU standards.
> But the really disturbing thing about the UK is that there are many people in power to whom human rights are less important than "souvereignty".
You could just as easily wrap "human rights" in air quotes here. The idea that human rights are universally agreed upon is silly. Further, even when human rights are agreed on there are always conditions to them. Yeah, you have a right to free expression so long as you don't express the wrong things. Yeah, you have a right to liberty so long as you don't do the wrong things. If you're concerned about human rights then you should also be fundamentally concerned about sovereignty because without sovereignty who exactly is deciding on the rights that should be protected? "Rights" that are prescribed upon a population without its consent can be oppressive, and right or wrong, this is clearly how a lot of people in the UK feel towards rules created by lawmakers in the EU.
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On the this topic more broadly as a Brit I am much less concerned about websites tracking me without permission because there are things I can do to prevent that. If you're concerned about data protection I'd argue you should be more concerned about the perfectly legal real-world privacy violation that you have little to no ability to protect yourself from. For example, in the UK our communication devices (internet traffic, SMS, etc) are monitored, our streets are full of surveillance cameras, supermarket self-serve checkouts implement facial recognition without our consent, the police stalk the public on social media to ensure we're not saying anything offensive. Given all of this why should I care if tesco.com has placed a tracking cookie on their site without my consent? It seems so trivial to the point that it's almost a distraction from the real privacy issues that we face as a society. I'm not going to be locked in a cage because Tesco put a cookie on their website, but what the government decides to do with the data their collecting on me who knows. The only reasonable way I can protect myself from that is by not saying things my government doesn't like online and not attending protests or other real-world events that my government may not approve of.
The rules that were "imposed" on us by the EU were often written by us. We had a huge hand in setting those standards.
If we want to do business with the huge market next door, we will have to abide by those rules, whether we have a hand in setting them or not.
I guess we can turn inwards and become poorer, both economically and culturally. Or we increase the red tape our businesses have to deal with if we want to expand our markets.
If you're optimising purely for economics then I don't think there's any question that remaining in the EU would have been the right decision. And yeah, I agree that sometimes compromise is just the cost of doing business.
The mistake you and a lot of remainers make though is to think Brexit is primarily about economics. Most of my family are on benefits and literally couldn't give a damn about what's in the best economic interests of the UK. I'm not saying that's right, but it is what it is. The problem people from my background have are more related to the social impacts of mass-migration and a lack of economic opportunities for low-skilled workers. From what I could understand that's why most of my family voted Brexit while most of my colleagues and university friends opposed it. I suspect the things that impact mine and your quality of life are different from that of my family.
I do think there's a place for an EU-like political entity that can set trade standards for the continent to encourage cross-border trade. The fundamental issue for me is that the EU as an organisation seems to be heading in the wrong direction. I'd personally prefer power to be more localised and closer to communities, where as the EU as an organisation seems to believe the trend should be in the opposite direction, towards ever more centralised power.
And they have a point.. If every nation state operates by different rules that's not good for multi-national corporations. But perhaps that's okay. Or at the very least it seems to me there's a trade off here. If there are things we can all agree on then it makes sense to have common rules, but enforcing agreement via a political union (or via any other means) generally isn't stable when opinions are too diverse. We see this even within the UK as political entity, but historically it's also clearly been true.
I guess what I'm saying is that perhaps what you see as economic costs have benefits which you might not appreciate as someone who largely agrees with the politics of the EU. It's like arguing to a Scot who dislikes the politics of Westminster that they'll be slightly worse off if they vote for Scottish independence. I think they get that, but they probably see the political opportunities of an independent Scotland as more important even if it comes with an economic cost.
I am indeed a remainer, although I was not motivated primarily by the economics. I just felt European, and mostly glad to be part of it. I could see problems with it, but nothing is perfect. I believed we would all likely be poorer out of it.
I get the immigration issue was important to many people, although immigration is now higher than it was before Brexit. Just not from the EU.
Everyone had different reasons and motivations at the end of the day, rightly or wrongly as it may turn out. I am glad we can have this conversation though, it's still rare I find.
Edit: tried to find source for my claim migration is higher, as I remember seeing it, but can't find it. ONS says from 2021 it was down a little bit overall.
Multi national corporations don’t really care whether the rules are homogenous or not, they’re big enough to do whatever they need to to sell their goods and services in whichever markets they want. The single market was actually more of a benefit for smaller companies, allowing them to sell to 500m people without having to worry about customs declarations, country specific safety certifications etc. There are many many examples of small producers having to stop selling to EU customers after Brexit because of the added cost and bureaucracy.
True. But it's not silly to think that the UK, as a signatory to the EHCR did agree on what human rights are with 46 other countries.
> "Rights" that are prescribed upon a population without its consent can be oppressive
Hm, either those air quotes are doing a lot of work, or we have different understandings of 'oppressive'. The only explanation I can think of for your statement here is that there are fairly limited circumstances in which the rights of one individual result in restrictions on the behaviour of another - for example inciting hatred, threatening violence, spreading untruths. I certainly wouldn't describe any of those restrictions as oppressive. Whether you want to call the limitations 'wrong' or not is ultimately a judgement decision, but for what it's worth, I don't think any of these are wrong.
> this is clearly how a lot of people in the UK feel towards rules created by lawmakers in the EU.
This is also true. But unfortunately displays the ignorance of many people in the UK, as the ECHR is not tied to the EU, so being cross with the EU about "human rights" is, although undeniably a contributing factor to the referendum result, basically a mistake. In fact the recent Rwanda flights were blocked by the ECHR more than two years after the UK left the EU.
> I am much less concerned about websites tracking me without permission because there are things I can do to prevent that
As an HN reader, you're likely more tech-savvy than most. Others may not be as easily able to prevent tracking. Additionally, some of the things you may want to do to prevent tracking may break core functionality. For example, I discovered recently that the Parliament TV website doesn't work if you don't download jQuery from a Google CDN. It seems to me to be an unacceptable requirement that in order to access materials which are produced with tax-payer money and are documentary evidence of our democratic processes, I have to share information with third party companies.
> If you're concerned about data protection I'd argue you should be more concerned about [...]
This type of argument is not helpful. I am indeed concerned about the things that you mentioned, but that doesn't mean that I cannot ALSO be concerned about websites tracking me.
> the police stalk the public on social media to ensure we're not saying anything offensive
Is there something specific you're thinking of here? I'm fairly confident that it is perfectly legal to say things which are offensive on social media. Here's Lancashire police's take: https://www.lancashire.police.uk/faqs/online-safety/someone-.... The CPS also has published guidance on this topic, although it's a bit heavier: https://www.cps.gov.uk/legal-guidance/social-media-guideline...
> Given all of this why should I care if tesco.com has placed a tracking cookie on their site without my consent?
I'll refer you to the excellent explanation at https://www.eff.org/deeplinks/2013/06/why-metadata-matters, but I would say that I'm a bit concerned that perhaps you don't really understand what the risk is here (or the technology at play).
Tracking cookies are placed on YOUR computer, not on a site. If you visit tesco.com, log in and do your online shopping, then Tesco might have a cookie set on your computer which contains your user ID. Now, you've finished your shopping, and you go to your local sex shop's website. Now, assuming there's a network request from the sex shop's site towards Tesco.com, they'll be able to see that user kypro accessed https://ilikebigbutts.com. Now, Tesco is not really a big threat here because there's no reason for Tesco to work with the sex shop, but companies like Google or Facebook encourage webmasters to include like buttons or tracking code for analytics etc. in order to gather this data and sell access to you to advertisers.
> not attending protests or other real-world events that my government may not approve of.
This for certain is especially worrying given the Police, Crime, Sentencing and Courts Act. But I think this is called the fallacy of relative privation in formal terms - just because one thing is bad, and another relatively less bad, does not mean that the second thing is not also bad.
“A radical Financial Services bill, drawn up by former chancellor and Tory leadership contender Rishi Sunak, will be published on Wednesday. It will pave the way for ministers to be able to “call in” regulatory decisions made by the BoE that they do not like.
“Nadhim Zahawi, who succeeded Sunak as chancellor this month, will endorse Sunak’s plan for a more “growth-focused” approach to City regulation in his Mansion House speech on Tuesday.” [1]
[1] https://twitter.com/financialtimes/status/154877322926693171...
[2] https://youtu.be/HDq13Lr2ZWw
[3] https://www.gov.uk/government/news/government-sets-out-plan-...
Bring in more countries with different set of rules, and lots of technological development will be blocked because of trying to deal with different laws instead of the creative freedom and time to do actual work in good ol' free web.
Ironically the good old web would work flawlessly
If you simply send documents and do not retain users data and do not track them, you'll be fine everywhere
If I remember correctly by default Apache kept a single log file and didn't log individual virtual hosts
the default log format doesn't save the host being called and the ip address is the one received by the socket, so it might be the ip address of a proxy server
hardly tracking stuff,but can be easily turned off
It's against freedom.
It would be OK if UK became more like the US but UK is not USA, in USA people don't usually get knocked on their doors by the police for their tweets. UK politicians have this desire to control the speech on the Internet, they work on stuff like identity verification when visiting porn sites.
People can be for or against Brexit in the context of government size and reach discussions however I don't see UK as getting more "free-markety" like US but more like Northern Europe style control with extra distance between the state and the people. It kind of feels like a combination of worst from the both.
when did this happen in UK?
Do you mean people broke the law with their tweets (which is like robbing a bank and showing your id to everyone there) and had to face the consequences of their actions?
[0] https://www.theverge.com/2022/2/7/22912054/uk-grossly-offens...
[1] https://english.alaraby.co.uk/news/uk-police-arrest-11-racis...
exactly.
they broke the law.
they would be arrested too if they shouted those tweets in public.
no surprises here.
just people stupid enough to break the law in public on a private platform that knows more about them than their parents.
Nobody knocked on anybody's door.
they have been found guilty of breaking the law by a court.
they have (and had) a right to defend themselves.
Unless you think that UK courts decisions are illegal, everything's looks fine to me.
So what? Alan Turing broke the law by doing gay stuff and was legally castrated. I'm sure things happening in Iran, Turkey, DPRK, China and Russia are mostly lawful. Slavery was lawful in many western countries up until a point, which is not too much in the past.
I would't invest too much on the "it's the law" argument outside of the courts. The legal laws are not forces of the nature, they are not like the laws of physics. They are made up.
I'm talking on the approach on the speech control. UK is more like the continental Europe. Let's say EU is using metric speech control when UK working with imperial ones and USA doesn't do that.
please not this again!
it's so tiring!
they broke the law knowing it, but hoping to hide in the anonymity of a tweet.
They hid because their actions were miserable and they knew very well.
stupid people doing stupid stuff and being caught.
no need to use Turing to justify the actions of drunk and violent racists.
let Turing out of it, please.
Anyway, these people have rights, nobody took their right to a defense in a due process away.
they have been found guilty by a regular UK court.
Not by a three letter agency that makes people disappear or the other one that brought Aaron Swartz to commit suicide.
And not in the 1950s, but few years ago.
I very much prefer to prevent it than dealing with it like USA does.
> 'm talking on the approach of the speech control
thanks god UK doesn't allow white supremacists to corrupt the minds on the youths that end up shooting to kids in schools.
People have been arrested for misgendering people. It’s total control of the speech, but total control of speech is acceptable in democracies because it is what people want. Apprently.
Web should be free, websites/services shouldn't be wasting time trying to comply with various laws but focus their resources on actual creativity and R&D.
In layman's terms, in my service's/app's privacy policy I should be able to say "I can do whatever I want with your data and keep it forever. Not OK with that, well don't use my service then."
No one's forcing anyone to use anything anyway.
That is what freedom is, blocking people from creating stuff is not.
Ah, okay, so you want to ignore the basic human rights of your users. Data protection legislation is necessary to protect us from you.
Well, to be fair the EU GDPR rules are easily summarised. They basically say: "Don't be an asshole with someone else's data".
Most sane people don't want the sort of filth that data hogging developers and their employers try to insist on imposing on their unwilling victim.
Get rid of the trackers, the un-necessary cookies, don't sell your user's data to the highest bidder, don't spam your users, you know the sort of thing .... and you'll be just fine under EU GDPR.
The reason all that detail is important is that the new Prime Minister will select an entirely new set of ministers. So basically, someone new will be responsible for coming up with this legislation and getting it through parliament by the 5th of September.
But surely we could make a lot of progress on this bill in parliament before September?
Well, you would think that's the case, but Parliament goes on their Summer holiday today. Guess when they come back to parliament - that's right! The 5th of September.
In UK there is the house of lords and the indirect election of the prime minister.
Such a horrific plausibility it doesn't bare thinking about, but I suspect the rank and file Conservative members might have a problem putting a brown man in charge, even if the alternative is as incompetent as the incumbent without the "charm".
> This I think could lead to a referendum to rejoin the EU
Unlikely.
> which I think would probably win
Even more unlikely.
Brexshitters would insist upon some sensible rules, such as 70% (or more) in favour for it to pass. I'd guess a vote today would likely be similarly split as last time, only just slightly in favour to rejoin.
Just wait until she gives Boris the Foreign Secretary job...
> Unlikely
Agreed - it's all very unlikely but I'm hopeful!
For a start, rejoining would mean (committing to) adopting the Euro and joining Schengen, which as a Brit living in the Schengen/Euro Zone I don't really see any advantage of and even less public support from within the UK.
Hopefully when the Conservative party, or at least its own current state, burns itself out, the cooler heads (from whatever party is in power) will move to something like the famed Norway/EEA model. It won't be framed as rejoin/remain, more just economic and trade policy, and it'll take the best part of a decade - but I consider that the most sensible 'optimistic' view on the future.
Yep, I agree, it's all very unlikely but I'm hopeful.
> rejoining would mean (committing to) adopting the Euro and joining Schengen for a start
I know I'm in the minority here but I'd absolutely love this. It just makes so much sense. We have such an island mentality.
At least we'd be part of a progressive union, even if its run by bureaucrats.
It may seem small minded but having to change currency, go through passport control, pay more import duty for shipments from mainland EU, reform the progressive data protection and human rights laws and renegotiate trade deals with the whold world is just all such a personal pain. A pain that I feel isn't alleviated by any benefits. Naming a single definit benefit of brexit is difficult - the Leave campaign was built on lies and the current "Brexit Opportunities Minister" Moggins isn't achieving anything noteworthy.
Now we can have two different sets of rules to comply with if we do business with the EU.
It is entirely ideological.
I've heard a few people saying things like "something should be done", but nobody outside of tech circles (and even many people within it) I've spoken to supports this bill, in fact none of them have even heard of it.
I'd say: if they're saying that they don't understand how the political system in the UK works
Remember when the plan was simply to add ID checks to adult websites, and how 2 years later that still didn't happen? If they couldnt get something that unambitious through, in years that were, relative to now, fairly stable, theres no chance they'd get this monster of a bill through. And thats before you add in all those bonus factors you mentioned.
There are some benefits to an incompetent government.
That said, isn’t there a significant probability that this gets voted in September anyway with nobody having bothered to read it?
> Great Britain is becoming Little Britain. The UK is like a giant Cayman Islands in 2016. They used to be the wise and perfidious grownups in the geostrategic room, but now it's all about squalid, petty things like Brexit, Scottish secession, anti-immigration; British political extremes are thriving and the middle is dead as mutton. They've lost their soft-power by the bucketful; people who used to beg for their wise counsel now ignore them. What do they want -- to be Airstrip One for any creep with a trailer-truck full of cash? I've never seen them think so small.
And a while ago the Tory party's Russian donors problem was in the news, including the son of an ex-KGB Gazprom owner who got a peerage. Whose party in Italy Boris Johnson the then foreign minister went to, alone. God damn, what a corrupt bunch.
However, this is all changing now. UK is keen to get rid of regulations it inherited from the EU, making it a much less attractive place to do business with, from the EU perspective. We can no longer assume that companies hosting EU citizen's data on UK soil will play nice and follow the same rules - it will be treated with caution initially, and (hopefully) with eventual hostility towards it, as UK seems to be going full on surveilence mode with government and its agencies having access to everything at all times with no warrants needed.
So yes, it "doesn't matter" only if UK isn't interested in working with the largest trading block on the planet. If they truly want to go that path, then sure, whatever.
This was never assumed under the current deal; the UK was given a grace period, which has now expired, before full enforcement, but on day one it was clear that inspection and/or barring of some goods (particularly food) would be necessary.
Can't send EU citizen data to a data centre in London if the EU says the UK's standards aren't high enough.
Feels like more of the same schroedingers brexit BS - “we want things to change but also stay the same”
For me, it caused the death of the European dream by a million tiny little cuts.
But surely it's possible to get rid of cookie popups without also giving away all of our digital rights?! Is this really the price we have to pay?
But what’s funny is, you’re right in a way. Many of the criticisms of the EU were just elaborate fictions concocted by right wing tabloids. We can add “GDPR caused Brexit” to that pile of falsehoods.
So although people now associate them with the GDPR, cookie popups were already an annoyance for many years before.
Unfortunately, the UK seems to be taking advantage of the (rightful) public backlash against cookie popups to also try to revoke many of the good parts of the GDPR.
If a site is asking for consent, they're either idiots who don't understand what the law requires of them or they intend on tracking their users.