Keith MilnerNov 23, 2022
Santa Claus
Oh dear. I've just been informed that collecting the names of every person on the planet for my naughty and nice lists is, and I quote, “a significant and wholly irresponsible breach of #GDPR “.
I'm going to hand out about 8 billion consent forms soon. If you could all get them back to me ASAP that would be appreciated.
Nov 22, 2022 at 12:22pmWeb
Show threadJamesGWilliamsNov 22, 2022

@Santaclaus I'd like to see the legal framework for assessing whether I've been 'naughty or nice' first please

Seems a very binary choice for such a complex issue

Show threadSanta ClausNov 22, 2022
@JamesGWilliams I've tasked this to an elf in our legal department, who is now alternating between shouting profanities and gently sobbing. I'll let you know when it becomes available.
Show threadJamesGWilliamsNov 22, 2022
@Santaclaus wow, someone needs an appraisal
Show threadPeteNov 23, 2022
@Santaclaus @JamesGWilliams if you’re not going for consent, you could use the favourite of the naughty lawyers who regularly get lumps of coal, “legitimate interest”!
Show threadYaoi Box BalloonNov 23, 2022
@JamesGWilliams @Santaclaus I second this.
Show threadFyzzlefryNov 23, 2022
@JamesGWilliams @Santaclaus masturbating is ok, union busting is not.
Show threadJamesGWilliamsNov 23, 2022
@fyzzlefry @Santaclaus call it even then?
Show threadWendyNov 22, 2022
@Santaclaus Santa. Please delete my data. I’m on the naughty list already. And I know it. Erase all me data immediately.
Show threadSanta ClausNov 22, 2022
@wmmanry I have been told I must legally comply, and thus it has been done.
While I am obligated to delete any and all recorded data pertaining to you, no-one can stop me forgetting which list you were on!
Oh no, wait, I've forgotten...
Show threadFyzzlefryNov 23, 2022
@Santaclaus @wmmanry You either eat too many cookies or not enough cookies.
Show threadNifty1ANov 25, 2022
@Santaclaus @wmmanry but do you keep a list of everyone who has asked to be removed from the other two lists?
Surely, you need to in case of accidenta re-addition?
The ln you need a list of those who have been removed twice...
Show threadWendyNov 25, 2022
@nifty1a @Santaclaus agreed. We require policy redundancy. #gdprcompliance. We have to ensure total policy efficacy.
Show threadBeeCycling has movedNov 22, 2022
@Santaclaus Do I need to include a mince pie and a glass of sherry when I return the form?
Show threadSanta ClausNov 22, 2022
@beecycling Not legally, but I'll never say no!
Show threadJottt 🦦Nov 24, 2022
@beecycling @Santaclaus might be considered a bribe. Be careful with such things.
Show threadRebecca Gellman, with 🤗🤓Nov 22, 2022

@Santaclaus I officially declare, publicly, you have permission to put me on the nice list, but definitely not on the naughty list (ahum).

Incidentally, I suspect you can reduce the figure of 8 billion by taking religion into account....

Show threadBenjamin Hollon 🇺🇸🇲🇾🇮🇳🇦🇫Nov 22, 2022
Let me know when and I'll go check my PO box. Hopefully it won't arrive while I'm out of town for Thanksgiving. ;)
Show threadMick MuldoonNov 22, 2022
@Santaclaus Can I just check that you have the required certificate for working in confined spaces, please? Chimneys qualify under recent revisions.
Show threadRob Nov 22, 2022
@Santaclaus I can help with that..
Show threadstd::polarNov 23, 2022
@Santaclaus Honestly, it seems that Santa has suddenly become much more inclusive for some reason. 8 Billion beneficiaries is ... many orders of magnitude target audience increase.
Show threadErnie SmithNov 23, 2022
@Santaclaus This is a genuinely good joke, no notes
Show threadAbby 🏳️‍⚧️Nov 23, 2022
@Santaclaus Wouldn't a letter soliciting Santa to supply goods imply inherent consent to recording customer names, addresses, and purchase information?
Show threadGarethNov 23, 2022
@abby @Santaclaus Probably not under European law... Santa has my sympathies, and if a Giant Propel in M/L should find it's way onto my living room floor... (or a Dolan Ares...)
Show threadAbby 🏳️‍⚧️Nov 23, 2022

@GarethTheBike @Santaclaus what's great is that at least one lawyer has written on this...

https://www.morton-fraser.com/insights/santa-gdpr-compliant

Is Santa GDPR compliant? | Morton Fraser Lawyers

The General Data Protection Regulations will come into effect in less than six months, so on a light-hearted note, the new provisions have been applied to our favourite chubby resident of the North Pole.

Morton Fraser
Show threadIslanderNov 23, 2022
@abby @Santaclaus He's going to need explicit rather than implicit consent though. The good news is that he only has to do this for the EEA and the UK.
Show threadʞuᴉԀ ✅Nov 23, 2022
@islander @abby @Santaclaus Might not be worth bothering with the UK, pretty sure the current crop are going to axe all that 'pesky' privacy legislation that's getting in the way of profit as soon as they can.
Show threadBradley 🤙 Nov 23, 2022
@Santaclaus @goaldeebug 😆
Show threadGoaldeeBugNov 23, 2022
@Santaclaus add a check box. “Please add me to your list” 😆
Show threadKamyar KojouriNov 23, 2022
@Santaclaus it’s too late! It’s not just the names you’ve been collecting for your naughty list, you’ve been accepting all our cookies too.
Show threadDan HonNov 23, 2022
@Santaclaus okay but did you consent to all of those cookies we left out
Show threadNodir 🇺🇦Nov 23, 2022
@Santaclaus you might have to go multi-region
Show threadLeo SaumureNov 23, 2022
@Santaclaus Use google forms.
Show threadHilde AustlidNov 23, 2022
@Santaclaus The Norwegian data protection agency warned you about this a year ago: https://www.datatilsynet.no/aktuelt/aktuelle-nyheter-2021/juletilsynskalender/luke-1/
1. desember

Juletilsynet er i gang. Det første vi sjekker, er julenissens påståtte registrering og kategorisering av barns handlinger. Dersom det virkelig er snakk om et register over alle barn på kloden, er det potensielt de …

Datatilsynet
Show threadToni M.Nov 23, 2022
@Santaclaus maybe a legitimate interest, instead? 🤔
Show threadDatendealerin 🎃☕Nov 23, 2022
@mad @Santaclaus Agreed, Santa! This "processing is necessary for the performance of a task carried out in the public interest" (Art. 6 e, #GDPR) I hope this info gets me on the nice list ✌️
Show threadTristan HendersonNov 23, 2022
@Santaclaus Please consider this post a GDPR Article 20(2) data portability request for all of my personal data in a structured, commonly used and machine-readable format. I would like to transmit my data to Krampus (once I can find his Mastodon account).
Show threadBundyoNov 23, 2022
@Santaclaus Would be much easier to just block Europe and California, like US web does. 🤷‍♂️
Show threadotherNov 23, 2022
@Santaclaus
Show threadberkes 🐝 🚐 🏄 🌱Nov 23, 2022

@Santaclaus wait? 8 billion? You have people on your list who don't even know you, or never celebrated Christmas?

I can imagine the wrath of your PII is fierce! 😋

Show threadEcosaurian 🏴󠁧󠁢󠁳󠁣󠁴󠁿 Nov 23, 2022
@Santaclaus
If you are only delivering gifts to children, why are all the adults on the list?
Or have they been left on the naughty lust by default - in which case you're right, to comply with GDPR they need to be forgotten and the data deleted.
Show threadDenise SuttonNov 23, 2022
@Santaclaus welcome to my world, Santa. By the way, I have been quite shockingly naughty this year.
Show threadCorvinNov 23, 2022
@Santaclaus
Show threadFerdi F. Zebua 🌏Nov 23, 2022
cc @nolan #WeirdMastodon #SupportTheWeird #WeirdIsGood #NoShame ✊
Show threadDerek McAuleyNov 23, 2022
@Santaclaus the scope for misuse is terrifying
Show threadCycling JudyNov 23, 2022

@Santaclaus

Dear Santa,

Please take me off your list. Over-consumption is destroying the planet, so I would rather not be part of it.

Judy

#noWasteChristmas
#GreenChristmas

Show threadMiley Crisis ☭✨Nov 23, 2022
@cyclingjudy @Santaclaus I think Santa's methods are sustainable, and he probably has the option for ethically and sustainably produced gifts
Show threadCybermatronNov 23, 2022

@Santaclaus Two things:

1. consent can probably not be used as a legal basis here as it will not be freely given, if not giving it results in a loss of presents;

2. the use of that data for that purpose could be considered to violate the fairness principle at least so far as vulnerable populations are concerned as it could lead to stigmatisation, for example of children, which could affect their life chances and limit their opportunities in the long term.

Show threadJustin FerrellNov 23, 2022
@Santaclaus @donmelton and now Santa can only have necessary cookies.
Show threadFábio Costa 🐇🕐🎩☕Nov 23, 2022
@Santaclaus as long you treat correctly the data and scrap it when no more needed, I believe it's okay
Show threadAndy WoottonNov 23, 2022
@Santaclaus I predict a less than 50% return rate.
Show threadJonathan Kamens 86 47Nov 23, 2022
@Santaclaus Hi Santa! You might be able to reduce your work a bit by not handing out consent forms to the billions of people who aren't, you know, Christian. hth kthxbye
Show threadConfusion as a ServiceNov 23, 2022
@Santaclaus Hi Santa, just a friendly reminder to make sure you relocate your elves in Groenland or Iceland, to avoid filling out a Transfer Impact Assessment. If you are still in Canada (postal code still H0H 0H0?) then it shouldn’t be too bad
Show threadPanda  Nov 23, 2022
@Santaclaus can I send via netcat?
Show threadSanta ClausNov 23, 2022
@n3xdp I do apologize, I'm getting somewhat flustered with all these different terms. Is this what you mean?
Show threadLisa Quilty HillNov 23, 2022
@Santaclaus Dear Santa, 8 billion seems extreme after factoring in American politics.
Show threadKeith SchoenefeldNov 23, 2022
@Santaclaus @shortstack I strongly recommend you hire a compliance specialist. The GDPR only applies to residents of the European Economic Area, so you only need about 500 million forms.
Show threadGlitterdivan 💋💖⭐️Nov 23, 2022
@Santaclaus No forms here I bought my own Christmas present 😎
Show threadGerard Cunningham ✒️Nov 23, 2022
@Santaclaus Don't think you need worry, to be honest.
https://twitter.com/moylato/status/1070635924667666432
Tom Moylan on Twitter

“For the record, Santa is GDPR compliant: 🎅 no history of data breaches 🎅 acquires consent through letters 🎅 list is essential to present-giving contract 🎅 fulfills article 5 by halting delivery, erasing data on grown-ups 🎅 naughty can exercise right to be forgotten”

Twitter
Show threadSven Tiffe Nov 23, 2022
@Santaclaus Before doing so I'd like you to shed some light on your business relationship with the Coca Cola Company.