(I mostly agree with Paul, I'm just continuing the discussion for the beauty of 
it)

> You do not have to do what is "doable". You have to do whatever is 
> *practical*. Investing in armoured vehicles to transfer your data is 
> certainly "doable", but not really "practical".
Doable, practical, reasonable. 
I consider "doable" something that makes sense in a given context, but if you 
take it literally, yeah, that wasn't precise enough.

> unless it's sensitive information, it is probably fine to send it unencrypted 
> or using a lesser encryption [...]
> Most emails do NOT contain sensitive information
You probably don't know that, but you actually should know*. So in doubt, use 
encryption. Nobody will blame you for using it, but you could be blamed for not 
doing so. Even if your current system doesn't do encryption, it's the 
opportunity to check if another system could, and maybe upgrade. Not having the 
proper tools isn't an excuse.

> People often think 'Ooh, my emails are sent using TLS1.3 encryption - no one 
> can see them, they're safe'. Nothing could be further from the truth.
Using TLS1.3 for emails is a step towards securing data. Man in the middle is 
not impossible, but harder to do. Not doing TLS because "pff the whole 
transport isn't 100% secure anyway" is, in addition to a bad idea, clearly 
reprehensible.

* I'm using "you" generally, not specifically about Paul. If you are an ESP, 
then you should have a data privacy agreement with your clients to describe 
what content could be there and what is done with it. If you're a sender using 
an ESP, you should have a DPA with your provider, and ask them to enforce TLS 
and other "practical" methods to secure the transportation of information.
--
Benjamin 

-----Original Message-----
From: mailop <mailop-boun...@mailop.org> On Behalf Of Paul Smith
Sent: mardi 18 décembre 2018 15:45
To: mailop@mailop.org
Subject: Re: [mailop] TLS Statistics

On 18/12/2018 13:54, Benjamin BILLON wrote:
> One of the basic principles of GDPR however is that whatever doable should be 
> done to keep personal information safe. So if you have the feature to use 
> encryption, you must use it. Nowadays in Europe, opportunistic TLS would be 
> the bare minimum.

You do not have to do what is "doable". You have to do whatever is *practical*. 
Investing in armoured vehicles to transfer your data is certainly "doable", but 
not really "practical".

So, yes, if strong email encryption is available, use it, but if it's not, 
then, unless it's sensitive information, it is probably fine to send it 
unencrypted or using a lesser encryption. Your data risk assessments should let 
you know whether that's OK or not. GDPR is quite pragmatic in that way.

Most emails do NOT contain sensitive information. Email addresses & names are 
not 'sensitive information'. Financial & medical details are 'sensitive 
information'.

If you had to use encryption, then using session encryption will most 
definitely NOT keep sensitive data safe. The mail could be processed by or 
stored by multiple servers, including those which may not be subject to GDPR 
and those will have access to the message data if you are only using session 
encryption. The details & locations of the servers which can access the mail 
data will not be known to most email users (in fact, unless both sender and 
recipient mail admins get together to discuss it, NO ONE will know which 
servers have access to a particular message)

People often think 'Ooh, my emails are sent using TLS1.3 encryption - no one 
can see them, they're safe'. Nothing could be further from the truth.


-- 


Paul Smith Computer Services
Tel: 01484 855800
Vat No: GB 685 6987 53

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