Brian,
I’ve read through the link you furnished for four “easy” steps to compliance.
Needless to say, the information presented there seems to summarize their opinion, but may I follow on saying the vague gist of their arguments is in conflict with the advice our outside attorneys have given after a 6 month effort to understand this.
Confusion reigns.
One key part of the link’s discussion is the realization that IF you have a non-EU location, they have no way in hell of assessing any penalties on you, even if they come to the conclusion that you violated this provision.
With software such as yours where users can download to try, and then buy later, it would be very difficult to gather the permission that this new law requires in a manner it requires, such as silence, pre-checked boxes, and so on.
And your concern about a world map of your software’s installations is also interesting, since it can’t really give you name, face, address or even audio recording of that information.
If you were to just provide a pin on a map with the city, and no link to the web page of the individual to see their weather data, I cannot fathom how that would be identifying. I’ve not looked at that in some time, but don’t know how that is set up currently.
The web site you provided is interesting and today I will contact our privacy officer to share that and discuss her understanding of it.
This whole thing is such a mismash, and I’m thinking that any politician who has stuck his or her foot in the mouth can suddenly declare that he wants all his video and audio recordings to be forgotten. Now what? I’m thinking that will bring a real challenge to the conflict between media and the elected liars (at least this is what they are called in the USA)
The implication from this web link you’ve referenced also has enormous over reach. Yes, a person may live in the EU, but they are interpreting this to mean that even non-EU places must obey their rules. Well, when in Rome do as Romans, and this ain’t Rome. To imply we out of EU folks give a flying darn about their laws if we don’t have a physical presence there is laughable. We in the USA have some laws about freedoms and rights, yet while there are groups who oppose oppression of women and allow them to drive and vote, the mid-eastern kingdoms have more concern about a fly than our anti-discrimination laws.
Mark Twain (Samuel Clemens) was a brilliant writer and cynic and political satirist in the 1800s. He wrote (supposedly) that in a town too small to support one lawyer, two will live quite nicely. I think there will be a LOT of lawyers’ fees generated over this one. Even a non-lawyer like myself can see obvious contradictions in this first attempt at a law to give enormous protection to EU citizens (but not all citizens of this planet.) One comment I read was it seems that the provisions of this law were collected during an afternoon and all night drinking session in which people yelled out ideas that seemed good but hadin’t been vetted for legality, possible enforcement, or even the standard to be used to judge compliance.
I’ll see if our legal and privacy office has a reaction to the web site.
Oh, one last Mark Twain quote. If one wishes to stay out of trouble, stay at home. In bed. Alone.