Kevin Yun

Office CCTV is lawful under GDPR, but consent is the wrong basis and signage alone is not notice. Retention and access requests are where it breaks.

Posted by Kevin Yun | 2026-08-27T18:46:23.340Z

Portability is narrower than access. It only covers consent and contract processing, and only data the person provided, including what you observed.

Posted by Kevin Yun | 2026-08-27T18:43:00.901Z

Article 22 is a prohibition with three exceptions, not a right people have to claim. It also catches ordinary rules engines, not just machine learning.

Posted by Kevin Yun | 2026-08-26T18:47:02.048Z

Pseudonymised data is still personal data and fully in scope. Anonymised data is outside GDPR entirely. The test is not whether you hold the key.

Posted by Kevin Yun | 2026-08-26T18:44:48.545Z

Session replay can be lawful, but two separate rules apply: consent to run the script, and a lawful basis for the recordings it produces.

Posted by Kevin Yun | 2026-08-25T18:34:38.467Z

You can monitor employees under GDPR, but almost never on consent. The test is necessity and proportionality, and the answer changes by country.

Posted by Kevin Yun | 2026-08-25T18:30:57.115Z

GDPR never mentions penetration testing. Article 32(1)(d) requires a process for regularly testing your security measures, a lower bar and a wider one.

Posted by Kevin Yun | 2026-08-23T18:13:11.764Z

GDPR does not mandate encryption. Article 32 lists it as one example of an appropriate measure, which moves the judgment, and the paperwork, onto you.

Posted by Kevin Yun | 2026-08-23T18:11:13.925Z

Sentry's DPA is opt-in and its EU region is real. The harder problem is that error reports capture personal data nobody ever decided to send.

Posted by Kevin Yun | 2026-08-22T06:10:26.650Z