GPDR Complaints
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I have to present a project to give Internet access to a group of about 50 floors, the networking topic I have clear, a neutral router with wifi on each floor and that all will stop at their corresponding network switches and a pfsense that will give access to all of them, with two or three balanced 600/600 fiber connections I have enough to give each floor 100/100 connections limited by switch mouth.
The problem is that in the project I am asked to comply with the GPDR (European standard) in which I basically have to be able to save for a month a series of data, for example:For each MAC address:
- Connection sessions
- Pages visited
- Device type
- Terminal operating system
- Navigator used
- Language
I know that by proxy this is possible, but I am not sure if with the captive Portal it is also possible and more easily consultable and controllable.
Is it possible to do this with Portal Captive or are there better ways?
Thank you
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hi,
GDPR asks you to be able to give to an user the personnal data you are recording/using. It does not ask to save or record any user data.
therefore, you don't "have to be able to save for a month a series of data".
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@free4 Thank you but...
I'd like it to be so easy... :-)
The point is that I have sought legal advice and its reasoning is as follows:
By offering the Internet and being providers of a service that they must manage and administer, as well as collaborating with the State Security Forces in cases of ongoing investigations and for the identification of users related to crime from their WIFI network.
So it seems that somehow I have to be able to register some kind of access, although later we know as computer scientists that it is useless because there are a thousand ways to skip it :-(
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@virusbcn said in GPDR Complaints:
GPDR (European standard) in which I basically have to be able to save for a month a series of data
Your listing these two items if they are linked together some how.
Actually, they don't.
"Some one" (a company or other organisation) is asking you to record a lot of usage data.
"Some else" (the law) is asking you to ( well, look up what GPDR really is - it's to much to describe it with 'some' words) .... something else - they use a lot of words to make you understand : don't record any data.You agree with the fact that if you do not log anything at all, your are perfectly well in compliance with GPDR.
No data == no abuse possible. And know one can drop by later on to ask "all what I did, can I review that back - or have it removed ?"Btw : I'm not an GPDR expert, but I know what 'they' are asking to you : I'm running a basic captive portal in a hotel (France). I decided to log as less as possible.
And I do not collect 'mail addresses' or any other info so I can use or sell it afterwards.For short :
Say, a connected user opens a VPN after establishing a connection "because they don't trust public networks".
You still have the "Connection session and the MAC info", but not :- The rest.
Note that the MAC can be set to anything random ... and reset to something else any time.
Thus 'device' type will be nonsense - but can still be detected (== deducted) in clear http request (these are rare these days).Btw : why collecting "OS, browser and language" info ?
I really wonder what the motivation is for collecting this info.Combining a captive portal with a proxy can be done. I never did it.
pfSense handles the portal, and some other device should be used as a proxy (that's what I've been reading all the time).
Be ready to loose some hair, though, most traffic is TLS (https) these days and no proxy can 'inspect' that traffic. In a near future even the https clear URL will get encrypted and then the 'collecting' will be minimal.Some good news : GPDR : from what I make of it, legally, you can do (collect) what you want, as long as you - or the one that stole your logs - don't 'use' the data without he "owners" knowing it. So, keep the logs on a secured site, and you'll be fine. Whatever happens, you are responsible.
As always, GPDR is something for the perfect world, and you and me. Not for the big Google, Facebook, etc ^^selling your data is what made them who they are.
By offering the Internet and being providers of a service that they must manage and administer, as well as collaborating with the State Security Forces in cases of ongoing investigations and for the identification of users related to crime from their WIFI network.
That true in most countries.
The POTS lines (remember - I work in a hotel - and people have phones in their room) and these days our Internet connections is on our (companies) name.
We are responsible for what has been done with. Now, I guess no one can manage it to launch a nuclear missile with a phone (voice) line - but I'm less sure what can be done with an Internet connection. So yes, better keep your user logged.
This can be done as we do : use vouchers - and log - on paper / scan / whatever user ID.
Video recording (we use a lot off cameras which helps me to see who was there when ...) -
@virusbcn Yes, you have to log, otherwise if shit happens you will be sort of liable.
Having said that, gdpr will kick in the moment you have personally identifiable information.
If you limit the information to mac address and there is no relation in the data kept between the mac address and the user, then gdpr is not applicable.
I would do it just like the providers do it. Log at the port/vlan level.
Then you know who did what at the unit level, and pass on any further responsibility. -
@netblues said "I would do it just like the providers do it. Log at the port/vlan level."
Interesting but I don't understand well...
How can this be done? -
@virusbcn Is there a separete authority at each floor, or you have to administer to the user level?
I suppose you don't want a flat network with everybody talking to each other in any case. -
@netblues said in GPDR Complaints:
@virusbcn Is there a separete authority at each floor, or you have to administer to the user level?
I suppose you don't want a flat network with everybody talking to each other in any case.Yes i don't want everybody talking with each other, that's why I thought of this system:
Router 600/600 ISP <---> <-> Neutral router (Tplink Archer C6) <---> (Apartment nº 1) <--- PFSENSE ---> <-> Neutral router (Tplink Archer C6) <---> (Apartment nº 2) Router 600/600 ISP<----> <-> Neutral router (Tplink Archer C6) <---> (Apartment nº 3) ...etcI think that by GPDR should log somehow the access of each house, either logging all traffic through the MAC of the neutral router or by users of captive portal, if you could log and search easily for example all traffic out of the neutral router of the Apartment nº 1 with the MAC xxxx would be great, but I can't think like what?
Otherwise I would have to do it by users of captive portal and ... little more ... -
Smart witches and most AP's can be set up to 'network isolating' these days.
This means that every connected device in the network can only communicate with he MAC that's being used by pfSense - in this case. Other network resource sharing will be impossible - connected users can't 'see' other devices on the network.
Even if the user selected a Home or Company type of network when he initially connects to your network.
This kind of network implementation is a basic for "non trusted" networks, as captive portal networks are.It happened to me years ago : I could 'see' all the holiday pictures on device that were used by my hotel client / captive portal user : the guy was sharing it's entire drive to the public "because it was so convenient at home".
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@virusbcn Instead of routers you could use vlans and managed switches.
You can have all vlans coming in to pf (cluster?) and assigning them different subnets
With one subnet assigned to each appartment its easier to log things.
Otherwise, hunting mac addresses will become a nightmare.
(unless you have an onboarding procedure where macaddresses are "let in"
(and then you have win10 changing mac addresses randomly, for "security")So its dhcp and pflogs, probably logged to an external syslog.
