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by anonymouz 2948 days ago
I also would prefer more clarity in the area of logging IP addresses, and would like to have a clearer consensus on what is allowed here. I think we will get a clearer picture after a bit of time.

It appears to me that as long as you don't use the logs for nefarious purposes you'd at least have legitimate interest in processing them (including the IP addresses), and so could keep them. This is the stance I am taking with respect to my personal webserver (together with a time limit after which logs are deleted); if a regulatory body informs me to change my approach, I'll gladly adapt.

Note also that IP addresses can be personal data, but do not have to be. Most claims here seem to relate to a ruling, where the IP address was deemed personal data in the hands of an ISP, who would be able to resolve it to a real person [1]. If you hold an IP address, but can't connect it to a real person (e.g. by having legal means to convince the ISP to give you that name based on the address), then it seems the IP address would not even be personal data in the first place. In the particularly ruling, the operator of the webserver was the German government, which presumably has more legal power to make an ISP turn over identifying data on a customer than a random website would have.

In any case, I hope some more clarity about this will emerge soon. But what you are talking about here would at best be a borderline infraction (and probably just be covered under legitimate interest). OTOH, what the person starting this thread had in mind seems to be that all the data he might collect on his users is fair game to do with as he pleases.

[1] https://www.whitecase.com/publications/alert/court-confirms-...