I’m very interested to see how this 1) gets enforced and 2) litigated. My curiousity comes from the practicality of enforcing anything to do with your example #1 from below.
-dan — Dan Brisson Network Engineer University of Vermont From: The EDUCAUSE Wireless Issues Constituent Group Listserv <WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU> on behalf of Philippe Hanset <0000005cd62f91b7-dmarc-requ...@listserv.educause.edu> Reply-To: The EDUCAUSE Wireless Issues Constituent Group Listserv <WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU> Date: Friday, April 6, 2018 at 1:55 PM To: "WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU" <WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU> Subject: Re: [WIRELESS-LAN] GDPR Lee, We have to follow GDPR closely due to the eduroam/Govroam/ANYROAM implications. Some of the logic behind GDPR is based on the location of the person whether EU Citizen or not. GDPR applies to all EU Citizens but also to visitors of the EU, and also to EU Citizens when using remote services outside of the EU (e.g. a EU Citizen signing for a Facebook account located on servers in the US is a GDPR case) Some edu examples: 1) A EU student registering for school in a US school while being physically in Europe is a GDPR case! 2) A US student registering for classes while being physically in the EU for an institution located in the EU (whether the institution is EU or US ownership) falls under GDPR. And then each of us has to look if we are Processor or Controller of the Data (or both!) and apply rules accordingly. Philippe Philippe Hanset, CEO www.anyroam.net<http://www.anyroam.net> www.eduroam.us<http://www.eduroam.us> +1 (865) 236-0770 GPG key id: 0xF2636F9C On Apr 6, 2018, at 12:52 PM, Lee H Badman <lhbad...@syr.edu<mailto:lhbad...@syr.edu>> wrote: Interesting- I couldn’t tell if rules were different between EU residents vs visitors. I’m sure a lot of campus legal departments/lawyers are busy right now trying to figure it all out. I’ll be curious to see how operations for US colleges abroad are specifically impacted from the network and IT perspectives. Lee Badman | Network Architect Certified Wireless Network Expert (#200) Information Technology Services 206 Machinery Hall 120 Smith Drive Syracuse, New York 13244 t 315.443.3003 f 315.443.4325 e lhbad...@syr.edu<mailto:lhbad...@syr.edu> w its.syr.edu<http://its.syr.edu/> SYRACUSE UNIVERSITY syr.edu<http://syr.edu/> From: The EDUCAUSE Wireless Issues Constituent Group Listserv <WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU<mailto:WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU>> On Behalf Of Caston Thomas Sent: Friday, April 06, 2018 10:46 AM To: WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU<mailto:WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU> Subject: Re: [WIRELESS-LAN] GDPR My understanding is that GDPR will apply to students & faculty visiting the EU on school related events (internships, foreign studies, conferences, trips), alumni traveling on behalf of the school. Logins & online activity from individuals in the EU will fall under GDPR. Logs will have to be purged or sanitized. For corporate entities, the cap on penalties is up to 4% of revenue. I am uncertain if that same amount applies to non-profit or educational institutions. I am, by no means, an authority, on the subject, so fire away if I’ve written anything that is inaccurate. But a close friend of mine has published a book on the topic. If there’s a high degree of interest, I can ping him for a good link or synopsis on GDPR for educational institutions in the US. Caston From: The EDUCAUSE Wireless Issues Constituent Group Listserv <WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU<mailto:WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU>> On Behalf Of Lee H Badman Sent: Friday, April 6, 2018 8:17 AM To: WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU<mailto:WIRELESS-LAN@LISTSERV.EDUCAUSE.EDU> Subject: [WIRELESS-LAN] GDPR Worthy of posting on both lists, apologies to those who will see it twice. Anyone feel like sharing what you've changed or are thinking about related to GDPR if you have network operations in Europe? The new regs go into effect May 25. -Lee Lee Badman | Network Architect | CWNE #200 Information Technology Services 206 Machinery Hall 120 Smith Drive Syracuse, New York 13244 t 315.443.3003 f 315.443.4325 e lhbad...@syr.edu<mailto:lhbad...@syr.edu> w its.syr.edu<http://its.syr.edu/> SYRACUSE UNIVERSITY syr.edu<http://syr.edu/> ********** Participation and subscription information for this EDUCAUSE Constituent Group discussion list can be found athttp://www.educause.edu/discuss. ********** Participation and subscription information for this EDUCAUSE Constituent Group discussion list can be found athttp://www.educause.edu/discuss. ********** Participation and subscription information for this EDUCAUSE Constituent Group discussion list can be found at http://www.educause.edu/discuss. ********** Participation and subscription information for this EDUCAUSE Constituent Group discussion list can be found at http://www.educause.edu/discuss. ********** Participation and subscription information for this EDUCAUSE Constituent Group discussion list can be found at http://www.educause.edu/discuss.
