What legal protections exist against doxxing in the UK Doxxing is the unfortunately growing phenomenon of having your personal data posted on public web sites, or even in commercial media (newspapers, TV/radio etc.) What, if any, laws does this break in the UK? What civil legal recourse is available? Does the amount and type of data disclosed matter? E.g., is just posting the real name behind a pseudonym much different to posting the victim's home address or employer as well? As a public service to any victims of doxxing, some advice on how to report it to the police would be helpful too. Most of it on the web is US-centric.
The primary protection against doxxing is likely to be the Protection from Harassment Act (1997) s 1: 1 Prohibition of harassment. (1)A person must not pursue a course of conduct— (a)which amounts to harassment of another, and (b)which he knows or ought to know amounts to harassment of the other. (2)For the purposes of this section, the person whose course of conduct is in question ought to know that it amounts to harassment of another if a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other. The amount only matters insofar as a reasonable person would consider it, in the circumstances, to be harassment of the other. Additionally, you may be able, if you show psychiatric injury, to pursue a tort of psychiatric injury against the perpetrator.
Copyright The photographer, not the subject(s) own the copyright in the picture. So, unless this was a selfie, you have no rights in the picture. Privacy If the photo was taken in circumstances where a reasonable person would expect privacy, then revealing it to others might be a tort of privacy breach. In most common law jurisdictions this area of the law is undeveloped. However, if the photo was taken from a public place (even if you were in a private place), or with your permission, this doesn’t apply. Intimate images In some jurisdictions, the distribution of intimate images without the permission of the subject is a crime. Intimate does not include a photo that is merely embarrassing. Bullying This is probably bullying behaviour but bullying per se is generally not illegal. It might be illegal if the bullying is motivated by a protected characteristic (race, age, gender, sexuality etc.) but that usually requires a context - employment, public accommodation etc. it might also be illegal hate speech even outside such an institutional framework. Similarly, within an institutional context like a workplace or school there might be policies around bullying; these might have the force of law but are probably quasi-contractural matters. However, a private person doing it because they don’t like you and want to humiliate or embarrass you is probably not doing anything illegal.
No You say you won't disclose personal information, therefore, you can't disclose personal information. Now, if your privacy policy said &quot;We won't disclose your personal information except ...&quot; then, so long as you did the &quot;...&quot; that would be fine (subject to privacy law).
Hate whoever you want The law doesn’t care who you hate, who you love and who you don’t give a rat’s behind about, nor does it care about your reasons for doing so. Similarly, the law in most advanced countries doesn’t care if you express your hatred in words. Write as many social media posts as you like decrying the imagined depredations of your hated groups. Record music and videos expressing that hate. Stand on a soapbox in an area set aside for such purposes and shout your hate to the world. Just remember, no one is obliged to supply you with the soapbox (actual or metaphorical). As an aside, there are some countries, which because of their history, have particular laws about what can and can’t be said about Nazis and Fascists (note the capital F). What the law does care about Violence - you can’t hurt people just because you hate them Harassment and abuse - you can express your hate but you can’t get in someone’s face to do it ”Hate speech” - which is not speech where you express hatred. It’s speech that incites or promotes violence against the hated group. Jurisdictions differ about where this line is. The United States requires the violence to be “imminent” meaning the speech has to be targeted to affect the audience to commit violence straight away. Other countries will crack down before that. Anti-discrimination law - which only protects certain groups in certain situations. For example, it is perfectly legal to exclude non-Catholics from taking Holy Communion. Similarly, the Labour Party convention is a ticketed event and they are perfectly free not to issue invitations to Tories.
It follows from case law from the ECJ, e.g. C‑70/10 (28 January 2010) and C-582/14 (19 October 2016), that IP-addresses are personal data. Since my interpretation of the case law differs from the interpretation offered by @Greendrake, I'll go into the relevant case law in a bit more detail than I did in my initial answer. TL;DR: Yes, IP-addresses in server logs are personal data and you need to declare IP-address logging in your privacy policy. As I said, we need to examine the case law I mentioned in the introduction to find out whether IP-addresses are personal data. The first of those are ECJ C-70/10. In this, the court concludes that all IP-addresses are "protected personal data": It is common ground, first, that the injunction requiring installation of the contested filtering system would involve a systematic analysis of all content and the collection and identification of users’ IP addresses from which unlawful content on the network is sent. Those addresses are protected personal data because they allow those users to be precisely identified. (my emphasis) Then, in 2016, the ECJ ruled in a more narrow case ECJ C‑582/14 specifically ruling on dynamic IP-addresses: The court goes through a number of deliberations, then concludes: Having regard to all the foregoing considerations, the answer to the first question is that Article 2(a) of Directive 95/46 must be interpreted as meaning that a dynamic IP address registered by an online media services provider when a person accesses a website that the provider makes accessible to the public constitutes personal data within the meaning of that provision, in relation to that provider, where the latter has the legal means which enable it to identify the data subject with additional data which the internet service provider has about that person. It is very clear from this text that the court does not challenge or invalidate ECJ C-70/10 on static IP-addresses. The court is very careful, in its ruling to point out its ruling is specifically about dynamic IP-addresses. So the ruling of ECJ C-70/10 still stands for static IP-addresses, these are always protected personal data. I believe this case law is summarized in Recital 30 of the GDPR. This recital lists the identifiers that may make natural persons identifiable: Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. (my emphasis). Since it follows from case law that static IP-addresses always makes the data subject identifiable, and dynamic IP-addresses may make the data subject identifiable, I will conclude, based on jurisprudence alone, that: Unless you are able to filter your logs to exclude static IP-addresses. I think you must consider IP-addresses protected personal data under the GDPR. However, in ECJ C‑582/14, the ruling about dynamic IP-addresses hinges on the controller having legal means to identify the data subject by connecting the IP address to some other data. The court seems to think that getting access to ISP logs is the only means of doing that. This is wrong. In 2015, the Norwegian computer scientist Einar Otto Stangvik identified 78 Norwegians who seem to have downloaded abuse material starting only with their IP-addresses. Stangvik did this while working as a consultant for Norway's larges newspaper VG. I know Stangvik and I am familiar with the methods he used. I've tried them myself, and they work. Stangvik did not have access to ISP logs, he did not do anything illagal, and the 78 natural persons identified only by means of their IP-address, combined with other data the Stangvik had legal access to. I will not go into details, I will just say this: If you know how to do this, getting to the natural person when you know the IP-address is not difficult or labour-consuming. To return to the question: It also follows from the GDPR that logging of IP-addresses falls under its definition of "processing". Your privacy policy should list all personal data personal data that is collected by yourself and third parties ("processors" in the terminology of the GDPR) that you rely on. Your hosting company is such a third party, and you need to declare the logging of IP-addresses in your privacy policy.
Nicknames, usernames, or gamer tags are definitely personal data under the GDPR. You are operating under a very narrow definition of “identifying”, which is understandable since the definition of personal data in the GDPR isn't overly enlightening at first glance: […] an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; — GDPR Art 4(1) However, this definition does show that “identifiable” should be interpreted rather broadly. For example, indirectly identifying data is still identifying data – there doesn't even have to be a strong identifier like a name, passport number, or street address. It is also not necessary that identification enables you to determine the real world identity – identification is anything that allows you to single out a person, or to combine data into a profile of that person (compare Recitals 26 and 30). In any case, an online username or user ID is clearly an identifier and will fall under one of “a name, an identification number, […] an online identifier”. If in doubt, ask your data protection authority for guidance. You've correctly understood that you will need a legal basis to process this data, and that legitimate interest could be that legal basis. This doesn't have to be your own interest, so a community interest would be OK. You need to balance the user's rights against this interest. You have performed this balancing and have found that the interest outweighs these rights. You've noted that such leaderboards are a cultural norm and are generally expected, which strongly weighs in your favour. However, legitimate interest is not a free pass but just means an opt-out solution (right to object per Art 21). You should also inform users that the leaderboard is accessible publicly when they join your server (transparency principle per Art 5(1)(a) as detailed by the information obligations in Art 13). In particular, you should use a “message of the day” or welcome message functionality to link to your privacy policy. You should also be aware that other rights such as the right to access, erasure, and data portability apply. As an alternative to legitimate interest (opt-out) you could also consider consent (opt-in), though this results in slightly different data subject rights and is more difficult to do correctly. But I'd agree that legitimate interest is more appropriate here.
Invasion of privacy and false light torts would probably not be applicable here. Very few states have adopted the false light tort because of its conflict with First Amendment principles and there was no agreement or even request to keep the text private. The copyright issue is trickier. First all, the TOS may provide that the copyright belongs to the text service provider or that there is a license. But, even in the absence of an express license, sending someone a message which is equivalent to sending them a letter, probably gives rise to an implied license that the person to whom it is sent can use the message that arises merely from the act of sending it without restriction or qualification. Implied license and fair use also heavily overlap. Publishing the text exactly as it was sent to you protects you from defamation liability because it is true. On the whole it would be extremely unlikely for there to be any legal liability for publishing a text from someone that they sent to you. Of course, one can imagine exceptions. If the person receiving the text was in an attorney-client relationship, or priest-parishioner making confession relationship, or was communicating regarding classified national security matters, or there was a non-disclosure agreement in place, among other possibilities, an evidentiary privilege and duty of confidentiality could apply and disclosing the material without the permission of the privilege holder could breach a duty of confidentiality and give rise to liability. If the picture was a nude picture of a minor, there could be a criminal and/or civil liability issue, and some states have also made posting "revenge porn" a criminal offense and/or a basis for civil liability. If the disclosure was effectively a way to facilitate insider trading that could be a problem. If the contents of the text were accurately transmitted but known to be false and were disseminated without disclosure of its falsity for the purpose of defrauding a third party, that could be a problem. But, no facts that obviously flag any exception are identified in the question. The mere fact that the posting may be embarrassing, or hurt someone's reputation, or was made without someone's express consent, in general, would not be a basis for liability.
Does GDPR prohibit reading unsolicited emails from people who have not explicitly opted in to a mailing list? tl;dr: No. I have never heard of this, and I don't see how this could follow from the GDPR. You should follow up with the Secretary to find out how she came to her conclusion. Detailed reasoning: The GDPR restricts the processing of personal data, so it does in principle cover reading email, since reading counts as "processing", and an email may contain personal data. However, Article 2 (emphasis mine) says that: This Regulation applies to the processing of personal data wholly or partly by automated means and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of a filing system. I would read this to mean that a human reading emails is only covered by GDPR if the emails are part of a "filing system" or intended to be. So reading the emails is ok, it's only problematic if you intend to systematically store them. Even filing them, while covered by GDPR, would presumably be allowed, because to actually act on the email, you would have to keep it, and Article 6 allows processing of personal data to "take steps at the request of the data subject prior to entering into a contract" and when "processing is necessary for the purposes of the legitimate interests pursued by the controller". One caveat: If the email contains data that falls under special categories of personal data (Article 9) you may need explicit consent for storage. That covers things like racial or ethnic origin, political opinions, religious beliefs and health information. So if someone discloses a health problem or their religious belief in their mail, you may need to ask them for permission to keep it. In summary: At most, GDPR would require you to promptly delete the email once you no longer need it (which could be immediately if the email is irrelevant to you). If the email contains data you legitimately need (e.g. a complaint you need to follow up on), you are allowed to keep it as required (based on Article 6 (f)). Note that in both cases no explicit consent is required from the email sender, unless the email contains particularly sensitive data, such as political/religious beliefs or health data.