If I’ve no WhatsApp account am I still a node on their social graph? And if so can I request to be deleted? I have never used WhatsApp so I have never shared my phone’s contacts with them or consented to their terms. Many of my friends and family do use WhatsApp and they will all have me in thier contacts under the same name and phone number. Therefore I must have node WhatsApp’s social graph? It might be only my name and number that they have, but It’s certainly enough for them to tie it to my Facebook account and to infer a profile of me by analysing the activity of the social graph around me. If this is the case do I have any right to ask WhatsApp to delete my node as I’ve never consented to be included? (I live in the UK).
I'm pretty sure that under GDPR, you can indeed request them to send all data they have on you. If it's a complex request, they may charge you something like £10. If they have a lot of data on you, they may list the categories of data they have and ask you to pick one, rather than them having to collect and send everything. They should respond within one month, but iirc in the UK implementation, they can inform you (within that month) that they will respond within three months instead. For the rest, I only know current Dutch law. GDPR is not that different from what we already had (in general terms) and in many cases it even extends it. Under our law (WBP), you can also request a correction of the data in case it is incorrect, or deletion if they no longer need it for the purpose for which it was collected and stored. I don't really know how that works out in practice though, as Facebook can of course claim that "being able to connect you to your friends when you sign up for WhatsApp or Facebook with that number" is a legitimate purpose (in their eyes). They might also not have your full name and therefore not be able to connect your data to your request. Or, perhaps, they have only your full name (and there are probably more people with your name), so they'll have a hard time verifying that it's really your data which they would be handing over or deleting. The company is required to verify your identity before acting on your request. How they implement that is up to them. Under Dutch law, if I remember correctly, any data that can be connected to your person by any party is personally identifiable information (PII). While Facebook might not be able to find who's behind a phone number, your carrier most certainly can. Therefore, the data falls under PII protection laws and they will have to implement a way to verify you and get you your data. Finally, whether your local laws apply to Facebook, I don't know exactly. There's lots of information on this though, so you should be able to find it. Generally, countries say that if something happened within their territory (e.g. you signed up for WhatsApp while in the UK), their law applies. Companies, I've read, will instead try to claim that their main office is in SomeCountry and therefore SomeCountry's laws apply. But I'm pretty sure you'll be able to find a Facebook office somewhere where GDPR applies, so that's probably fine. While not an exact answer and while I am not sure about everything, I hope this gave you some pointers to go on!
I assume this refers to the case covered here: https://www.theguardian.com/technology/2023/may/22/facebook-fined-mishandling-user-information-ireland-eu-meta The gist is: Under GDPR you can only transfer personal data from inside the European Union to the outside if you have procedures in place that ensures it is still protected to European standards. Facebook was found to have failed in that regards, specifically when it came to access by US spy agencies. It seems indeed quite plausible that it is not possible to transfer personal data from the EU to the US in a way that is compatible with both EU and US law. The EU and the US are in negotiations to find a way to make this legally possible. But until then, it seems that if you do have a European subsidary and want to keep all of your account data in the same place, it needs to be a place with robust privacy protections. That doesn't require it to be in the EU, but something like US, Russia or China would be illegal.
It doesn’t make you exempt from the GDPR if that’s what you’re asking The hash you produce is linked to one (or a small number) of computers and it therefore serves as an ID number. Because that ID number is linked to the owner of the computer it is personal information and if you are collecting it, you must comply with the requirements of the GDPR - valid legal reason, deletion when no longer required, deletion on request, data security etc.
I think haveibeenpwned would be legal in the EU because it carries out a task in the public interest (Art. 6(1)(e)), and it shares no more data then necessary, for example you can search for a password, but it would not show you the emailaddress which belongs to that password. It would also be legal for you to hold a copy of a leaked database, but only if you have a legitimate interest (Art. 6(1)(f)) to have it. Being a security company does not change that, but finding a legitimate interest might be easier. If you have a legitimate interest to hold a copy of a leaked database, it does not mean you can use it in any way you like. For example testing if the password still works, is very likely illegal everywhere in the EU. But I'm not familiar with the UK laws.
No. While UK data controllers must register with the ICO, they only have to provide general contact details. The ICO does not provide a public registry of data controllers. Outside of the UK, there is no requirement to register with the Supervisory Authority unless a DPO is appointed. Per Art 13 GDPR, every privacy notice must disclose the contact details of the controller, and of their DPO (if applicable). The GDPR does not require controllers to have a specific email address for data subject requests. Controllers have to fulfill the request regardless of the channel through with the request is made, so that normal channels for support or contact should be appropriate. The ICO writes in its guidance to controllers on the right to access requests: Are there any formal requirements? No. The UK GDPR does not set out formal requirements for a valid request. Therefore, an individual can make a SAR verbally or in writing, including by social media. They can make it to any part of your organisation and they do not have to direct it to a specific person or contact point. Of course, if a controller does not make contact details available or otherwise refuses to accept a valid data subject request, you can ask the ICO for assistance.
Since the Steam ID contains or may contain enough information for it to be possible to link your account to you as a physical person, it would definitely be considered "personal data" according to Article 4 of the GDPR. However, by agreeing to the DOTA2 terms of service, you have given consent for them to show your information to other players (or at least that is included in most terms of service I have read for other games. I have not read the one for DOTA2 specifically). Replays are an interesting corner case. If download of replays are only possible for other players or if the wording of the ToS says that you consent to displaying your user ID to anybody, that would mean that they would have covered their bases. As long as they comply with other parts of GDPR, like "the right to erasure" (Article 17) that is. If the API is accessible to anyone and not covered by the ToS you might have a case. If you only want to remove the traceability between you and the replays, you can always evoke Article 17 and delete your account.
TL;DR In theory there's nothing wrong with your method, it's just a way to authenticate the user, and without authentication a user has no right to request anything anyway. But in practice it looks like your method doesn't have a way to deal with situations where users lose or forget their authentication data and want to be able to recover their account. Failing to deal with that in a modern system might be considered an unacceptable bad practice and so be against the GDPR principles of security and privacy by design. EXTENDED VERSION I might be wrong or not understand the question correctly, but I don't see how this is different from many other common cases where encryption is not involved. Think about it, you aren't able to give the user their own personal data unless they provide the ID and encryption keys. How is this significantly different from the fact you aren't able to (or rather you should not) show a user their own data unless they provide their own username and password, or they convincingly authenticate themselves in any way? Just like you can't ask Facebook to show you all the data collected about Donald Trump only by claiming you are Donald Trump, you can't be required to give a user their own data unless they provide the encryption key. It can be seen as your way to authenticate users (among other things). Edited: multiple IDs/keys I didn't understand your method involved multiple IDs and keys. In theory, the situation is still the same, only with multiple pieces of data for authentication, like the user had to remember multiple usernames and passwords. Failing to provide all IDs and all keys will result in a partial authentication. But with such an approach a potential problem becomes more evident: your authentication scheme might be against the GDPR principles of "security and privacy by design and by default". Basically, your methods might be considered bad practice because they fail to deal with the common issue of lost or forgotten passwords. If a user tells you they have lost a USB drive containing all their IDs and keys and they don't have them anymore, what do you do? You can't delete their data because you aren't able to know what their data is, without another way of authenticating. And their data is now at risk, because somebody else might have their IDs and keys. If you had an email address associated with all the user's IDs and data, then you might be able to confirm their identity (for example sending an email with a link) and delete all their data. As you see, things can get pretty complicated, it all depends on the details of your implementation, and just adding or removing one detail might change the whole scenario.
Yes such a username would be personal data. It is information that relates to an identifiable person. In this context,a person isn't identifiable only if you can infer their real-world identity, but already if you can single out one person's records. Thus, your random IDs and any linked information would be personal data as well. Just because something is personal data doesn't mean that processing it is illegal. It just means you need a legal basis. That could be necessity for performing a contract with the data subject (like saving game progress), a legitimate interest, or consent. Taking into account GDPR principles like &quot;data protection by design and by default&quot;, it could be sensible to hide a players stats from the leaderboard until they give consent. On the other hand, you may have a legitimate interest to provide leaderboard data for ranking/comparison, especially if the leaderboard entries are pseudonymized. In any case, it should be clear to the users which information is visible to others.