Created on 29 August 2024, 8 months ago
Updated 19 September 2024, 7 months ago

Problem/Motivation

Just came across this module and whao, sounds GREAT!

Reading this:

By default, these signal types are enabled and will push the IP addresses upstream to CrowdSec while the blocking of those happens locally, independent of CrowdSec including them into their block list.

It sounds like the "free" mode is not GDPR compatible? Perhaps it would make sense to add some sentences about that on the module page *eventually*?
Sadly if I remember correctly, the IP address is treated as personal data, at least in Germany ... -.- (don't discuss that with me ;D)

My point is, perhaps it would make sense to make people think about it. Or not... I don't know.

Steps to reproduce

Proposed resolution

Remaining tasks

User interface changes

API changes

Data model changes

πŸ’¬ Support request
Status

Fixed

Version

1.1

Component

Documentation

Created by

πŸ‡©πŸ‡ͺGermany Anybody Porta Westfalica

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Comments & Activities

  • Issue created by @Anybody
  • πŸ‡©πŸ‡ͺGermany Anybody Porta Westfalica

    (What I wanted to say is: I hope I'm wrong and it's GDPR compatible even in free mode ;D)

  • πŸ‡©πŸ‡ͺGermany jurgenhaas Gottmadingen

    Well, I'm a strong advocate of the GDPR. I get upset if others do not respect my privacy, and often even hold them accountable. So, you don't need to defend why this might be an issue.

    However, in this case, there are 2 reasons why I believe that this is GDPR compliant even in the free tier:

    • All the processing happens locally, and only if an attacker is identified, will they be blocked and reported. As the victim of an attack, I should be allowed to report that as a matter of defence.
    • This is happening only to protect the site, so it's under the clause of operationally necessary data processing. Even more so, this is not to track visitors, it's only to keep the site up and running.

    I might be wrong, since I'm not a lawyer. But that's common sense. However, if you have arguments that prove this wrong, I'm happy to discuss this and do something about it.

  • πŸ‡©πŸ‡ͺGermany pminf Nuremburg (Germany), formerly Dresden

    This module integrates with the CrowdSec API using their PHP SDK to verify the IP address of each request getting to your Drupal site against their block list and should an IP be listed for being banned, those requests will be rejected and responded with a 403 HTTP response status code.

    No worries, the block list is cached locally, and no performance implications are expected.

    Do I understand correctly that the IP addresses of incoming requests are only checked against a local block list and are not transmitted to CrowdSec or other third parties? So the transmission to Crowdsec only takes place for suspected bad IPs in order to share them with the community?

  • πŸ‡©πŸ‡ͺGermany jurgenhaas Gottmadingen

    Do I understand correctly that the IP addresses of incoming requests are only checked against a local block list and are not transmitted to CrowdSec or other third parties? So the transmission to Crowdsec only takes place for suspected bad IPs in order to share them with the community?

    Yes, that's exactly right.

  • πŸ‡©πŸ‡ͺGermany pminf Nuremburg (Germany), formerly Dresden

    Here is a thread about this topic in crowdsecs support forum: Is CrowdSec acting against european privacy regulations?. It supports JΓΌrgen's argument in #2 that the IPs may be transmitted for security purposes (see also https://www.privacy-regulation.eu/en/recital-49-GDPR.htm). If in doubt, you can also deactivate the transmission (this may only be possible in the paid version).

  • πŸ‡©πŸ‡ͺGermany Anybody Porta Westfalica

    GREAT! Thank you both for the quick and comprehensive reply. Would it then perhaps make sense to put a heading "Privacy and compliance" on the project page, linking to this issue and the forum link?

  • Status changed to Fixed 7 months ago
  • πŸ‡©πŸ‡ͺGermany jurgenhaas Gottmadingen

    I have updated the project page and added a chapter about privacy and compliance.

    The text come from the README.md file in the repository. So, if there are any requests for changes or amendments, please open an MR with the proposed changes in that readme file.

  • πŸ‡©πŸ‡ͺGermany Anybody Porta Westfalica

    Thank you very very much for the clarifications @jurgenhaas!

  • Automatically closed - issue fixed for 2 weeks with no activity.

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