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Update here.

Scope of the download

All user-related records in user activity (record of likes, bookmarks, topics, replies etc) have been added to the download (commit).

I initially didn’t add this as it seemed like overkill. However @RGJ raised it with me and we had a productive exchange on the question.

Essentially, we decided that the best approach for the purposes of this feature was to include all records of activity tied to the user’s identifier that don’t entail countervailing concerns about the privacy of others or similar rights.

I would emphasise “for the purposes of this feature”, as the purpose of this feature is to take a ‘maximalist’ approach to possible interpretations of the GDPR. It does not attempt to parse ‘likely’ approaches. I’ve laid out some of my own views on the ‘likely’ approaches in this topic (which remain unchanged).

The specifics of the reasoning behind this ‘maximalist’ approach are:

  • The broadest interpretation of A.4.1 (the definition of ‘Personal Data’ in the GDPR) as it applies to Discourse is any record in the db that contains the user’s user_id, i.e.:

    any information … identified or identifiable natural person … identified, directly or indirectly, in particular by reference to … an identification number

  • Read literally, this definition doesn’t care about how the data is produced (e.g. whether the user is acting or not). It merely requires the data to be related to the user’s identifier in some way.

  • However, applying that literally would produce a fair amount of duplication (e.g. the records in the directory_items table are duplicative of various other entries).

  • The point of the extended download is to guard against even the small risk that Article 4.1 could receive a very broad interpretation by some authority or court in Europe.

  • The factors against including it - size of download, potentially security (?) - do not outweigh the possible benefit of including it.

We also considered whether to include ‘administrative’ records with the user’s user_id such as flags, complaints and staff whispers. We decided against this, reasoning as follows:

  • They’re already in the territory of information associated with the user purely by their identifier. They are not information about the user per se (i.e. name, email, age, location etc). This is already assuming a wide interpretation of A.4.1.

  • Whether administrative records intrude on the privacy of other parties, or other relevant concerns (i.e. R. 63.5 & A.15.4) must be determined on a case-by-case basis.

  • Other parties, such as Facebook, do no include such data in their user download functionality.

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