On Sat, May 26, 2018 at 4:57 PM Dan Hollis <goemon@sasami.anime.net> wrote:
I imagine small businesses who do a small percentage of revenue to EU citizens will simply decide to do zero percentage of revenue to EU citizens. The risk is simply too great.
That would be a shame. I would expect the level of effort to be roughly commensurate with A) the size of the org, and B) the risk inherent in what data is being collected, processed, stored, etc. I would also expect compliance to at least partially derive from vendor/cloud/outsource/whatever partners, many of whom should be scaled/scaling up to minimally comply. I would also not be surprised if laws of similar scope start to emerge in other countries. If so, taking your ball and going home won't be sustainable. If small, vulnerable orgs panic and can't realistically engage the risk, they may be selecting themselves out of the market - an "I encourage my competitors to do this" variant. Naively ... to counter potential panic, it would be awesome to crowdsource some kind of CC-licensed GDPR toolkit for small orgs. Something like a boilerplate privacy policy (perhaps generated by answers to questions), plus some simplified checklists, could go a long way - towards both compliance and actual security benefit. In a larger sense ... can any org - regardless of size - afford to not know their data, understand (at least at a high level) how it could be abused, know who is accessing it, manage it so that it can be verifiably purged, and enable their customers to self-manage their portion of it?? I'm personally a big fan of undue diligence and all, but we need to advocate for some ... realistic scaling of response. Royce