The Norwegian COVID-19 contact tracing app is banned by the Data Protection Authority

GDPR in the Wake of COVID Spread: Privacy under Pressure – Part 2

Our previous blog post in this series concerned mobile phone applications under development, or already developed, in various countries for tracing the spread of COVID-19 infections. In particular the blog described the situation in Norway, and we expressed our concerns, but also our trust, in the fact that The Norwegian Data Protection Authority (‘Datatilsynet’) would be on the spot to safeguard privacy – as regulated by strict Norwegian privacy regulations.

The Norwegian Data Protection Authority — more than a watchdog

Temporary suspension of the Norwegian Covid-19 contact tracing app
The Norwegian Smittestopp app

We were right, and we are proud of the intervention by the Norwegian Data Protection Authority (NDPA), which in June banned the Norwegian COVID-19 tracker app Smittestopp. The ban illustrates NDPA’s independency, and that NDPA has legal power to enforce privacy protection when public (and private) organizations violate the law.

This power is anchored in the Personal Data Act (personopplysningsloven), the Norwegian implementation of GDPR, and the Personal Data Regulations (personopplysningsforskriften).

After evaluating the app Smittestopp as it was implemented in April this year, NDPA concluded that the app violated the privacy legislation in mainly two respects:

  1. The app was not a proportionate intervention of the user’s fundamental right to data protection.
  2. The app was in conflict with the principle of data minimization.

On June 12, The NDPA notified The Norwegian Institute of Public Health (NIPH) that the app would be banned, which was confirmed on July 6. Consequently, NIPH immediately stopped collecting data from the around 600,000 active users of the app, and deleted all stored data on their Azure server.

What the requirement for proportional intervention means

The breach of the requirement for proportional intervention concerned the expected low value of the app regarding infection tracking, due to the relatively small number of the population in the testing areas actually using the app (only 16%).

The reason for the breach of the principle of data minimization was that the app was designed to cover three different purposes:

  1. Movement tracing of individuals (for research purposes).
  2. Spread of the infection among the population.
  3. The effectiveness of infection control measures.

The NDPA was also critical to the app because it was not possible for the users to choose for which of the three purposes their data would be used.

A new app is already being planned

The government has decided to terminate further development of Smittestopp, and will instead focus on the development of a new app. After seeking advice from NIPH, the government has decided to base a new app on the Google Apple Exposure Notification (GAEN) System, or ENS, which they call “the international framework from Google and Apple” because many countries (for instance Denmark, Finland, Germany, Great Britain) are going “the GAEN way”.

Important arguments for the government’s decision are that GAEN supports digital infection tracking only (Bluetooth-based), involves no central data storage, and includes the possibility to exchange experiences and handle users’ border crossings. In the meantime the EU has implemented a recommendation for decentralized Corona tracking applications, putting GAEN “squarely in the frame“.

NIPH was given the task to specify a request for proposal in an open competition for the development assignment of the new app, and now (October 20) the Danish Netcompany is hired to do the development. Netcompany has a similar contract with the Danish health authorities, and was the only bidder (!). The new app expected to be implemented this year (2020).

The privacy debate continues

Three main issues are still being debated, and the first is technical: Is Bluetooth reliable enough? Experiences show that false positives, but also false negatives, do occur when Bluetooth is being used.

The second issue is of course privacy. Even if personal data is stored locally on the phone, notifications between phones have to be relayed through a network – so what about hacking? In addition, Trinity College in Dublin has uncovered that on Android phones, GAEN will not work unless it is sending owner and location information back to Google.

This leads to the third issue: Is it sensible to let the tech giants control a solution that involves processing very personal information? “Do Google or Apple get to tell a democratically elected government or its public health institutions what they may or may not have on an app?”

The Norwegian Data Protection Authority published a report on digital solutions for COVID-19 (‘Coronavirus’) infection tracking on September 11 this year. The report was developed by Simula Research Laboratory, who did not bid on the contract for the new GAEN-based application (arguing that they are a research institution and not a software development company).

The report “… focuses on efficiency, data privacy, technology-related risks, and effectiveness for government use. In terms of privacy and data protection, the report notes that if location data is still stored by Google, the COVID-19 app Smittestopp would be less privacy intrusive than the GAEN one.”

Conclusion

We will conclude with a quote (in our translation): “There is no perfect solution for digital infection tracking. Effective infection control and privacy stand in opposition to each other.”

For us at Runbox, privacy is priceless, and we are still wondering if the pros outweigh the cons.

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Runbox doubles the storage capacity on all account plans

It’s our 20th birthday, and we’re giving YOU a present!

Our goal has always been to provide professional email services with massive storage space that is also affordable and flexible.

When Runbox was officially launched on October 12, 2000, Hotmail was the market leader with 2 MB storage space.

Runbox then decided to launch an email service with a whopping (at the time) 100 MB free storage — and received more attention (and signups) than we could have anticipated.

It’s now 2020 and we are doing it again, by multiplying the storage space on all our subscription plans by 2!

Our plans will now include storage space as follows:

Email StorageFile Storage
Runbox Micro2 GB200 MB
Runbox Mini10 GB1 GB
Runbox Medium25 GB2 GB
Runbox Max50 GB5 GB

These quotas will take effect for your account upon your next Runbox subscription purchase or renewal. So don’t forget to take advantage of the double subscription time on all product purchases through October!

Proceed to our Product page right away to automatically upgrade your account.

And we hope you will enjoy Runbox at least twice as much going forward. 😀

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Runbox Celebrates 20 Years with 2 Years for the price of 1 through October 2020

On October 12, 2000 the Runbox email service was officially launched, on an Internet that was quite different from what we are used to today.

Initially, Runbox was a basic email forwarding service with a permanent @runbox.com email address. The original idea was to eliminate the need for email users to inform their contacts about a new email address when they changed schools or work places.

We soon expanded the Runbox service with a custom made Webmail interface, and offered a whopping 100 MB storage space. This was substantial compared to the 2 MB offered by Hotmail, who was the market leader at the time.

At that time Runbox was a free service, and the offering brought international attention and a large number of users. We then expanded with POP, SMTP, and IMAP access, email retrieval and filtering management, file storage, and support for email domains and domain hosting.

In 2012 we were once again at the forefront by strengthening the security and privacy aspects of our services following the surveillance revelations especially in the US.

Since those early years we have founded a new employee-owned company, continued hardening the security and privacy of our services, and built new partnerships and new server infrastructures, while broadening the foundation of our operations to embrace strong environmental and ethical principles, a diverse and dedicated team, a global customer base, and an inclusive virtual organization.

Now we are hard at work making Runbox 7 the fastest webmail app on the planet. In a world that is experiencing several global crises simultaneously we are increasingly focusing on features that facilitate global interconnectedness, telecommuting, and remote work by making our service more people and activity centric.

In an uncertain future one thing is for sure: Runbox will reinforce our mission to help people communicate better, more efficiently, and in a more organized way.

To demonstrate this we celebrate our 20th anniversary by doubling the subscription time on all Runbox products and renewals free of charge through October.

This means that when you purchase a subscription or add-on you get 2 years for the price of 1 year!

Proceed to our Product page right away to take advantage of this offer.

Thank you to all the customers who have supported us through the years — here’s to the next 20!

Note:

  • The additional subscription time will be applied automatically upon subscribing.
  • All initial subscriptions come with a full 60-day money back guarantee.
  • Hosted domains and other third party purchases are exempt.

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GDPR in the Wake of COVID-19: Privacy Under Pressure

Tech companies all over the world are rushing to support health authorities in combating the spread of the SARS-CoV2 virus, which is causing the more well-known COVID-19 disease. Whether those companies do so by invitation, by commitment, or by sheer self-interest, country after country is embracing mobile phone tracking and other technological means of tracking their citizens.

It might be worthwhile to take a deep breath and understand what’s currently technologically possible, and what might be at stake.

Tracking the infection

Everyone wants to avoid infection, and every government wishes to decrease the consequences of the pandemic within their country. And modern technology makes it possible to impose on citizens surveillance systems that represents a significant step towards realizing a Big Brother scenario.

In fighting the spread of the virus, it is crucial to know who is infected, track where the infected are located, and inform others that have been, or may come, in contact with the infected. It is precisely in this context that mobile phone tracking is playing a role, and this is currently being explored and implemented in some countries, raising ethical and privacy related questions.

Smartphone tracking apps

Once tracking of individuals’ phones is established for this particular and possibly justifiable reason, it could be tempting for a government or company to use it for other purposes as well. For instance, tracking data could be combined with other personal data such as health data, travel patterns, or even credit card records. Or the location of the infected individuals could be presented on a map along with the persons’ recent whereabouts, perhaps supplemented with warnings to avoid that area. Privacy is under pressure.

A smartphone can also be used as “electric fence” to alert authorities when someone who is quarantined at home is leaving their premises, or to fulfill an obligation from the authorities to send geolocated selfies to confirm the quarantine. Some authorities even provide individuals with wristbands that log their location and share it with the relevant authorities. The examples are many, and they are real, underlining the ongoing pressure on privacy.

Big tech gets involved

Very recently two of the world’s biggest tech companies, Apple and Google, announced they are joining forces to build an opt-in contact-tracing tool using Bluetooth technology, and will draw on beacon technology as well. The tool will work between iPhones and Android phones, and open up for future applications one cannot currently imagine.

In the first version, the solution is announced as an opt-in API (application programming interface) that will let iOS and Android applications become interoperable, and — now comes crux no 1 — the API will be open for public health authorities to build applications that support Bluetooth-based contact tracing. The tool is planned for a second step — here is crux no 2 — an upcoming update of both iOS and Android will make the API superfluous. Of course, you can opt-out, but then you can’t download the operating system software update at all.

It is a double-edged sword: It is great that big tech companies are mobilizing resources to help in a public health crisis, but do we really want these companies to potentially know even more about our personal lives (in the name of the common good)? Privacy is under pressure.

Norway’s privacy oriented approach

Norway has also launched a mobile phone application to help limit the spread of the infection, but this development is done under the strict regime of privacy regulations and in accordance with the GDPR. The decision to implement the app was taken by the Government in a regulation containing specifications and strict requirements adhering to the GDPR is taken care of, including limited use until December 1, 2020.

It should be added that some of the exceptions in GDPR for authorities is put into effect because of the extraordinary situation. However, the Norwegian parliament (Stortinget) may terminate the law supporting the regulation at any time if 1/3 of the parliament members decides so.

Even if, at least in theory, it might be feasible to use a similar app from other countries, it is crucial that the software is developed from scratch in Norway. This will ensure that Norwegian authorities maintains control over all functions and data, and that the privacy regulations in the GDPR are respected.

It is also comforting that the app is developed in cooperation with The Norwegian Data Protection Authority (Datatilsynet). Other countries allow similar apps to store health information, access images or video from cameras, or even establish direct contact with the police. Such functionality is naturally out of the question in Norway’s case.

The app is designed and will be used for purposes of tracking the pandemic only, and installation and usage is voluntary. When installed and activated the app collects location data using GPS and Bluetooth, which is encrypted and stored in a registry.

In case of a diagnosed infected individual, health personnel will check if the person has installed the app. Individuals that have been in closer contact than two meters for more than 15 minutes with the “infected phone” will be notified by text message. The location data is kept for up to 30 days, and when the virus is no longer a threat the app will stop collecting data. The app users may at any time delete the app and all personal data that is collected.

What does it take to succeed?

In order for the tracking to have any impact on the spread of infections, around 60% of the population* must use the application. At the time of writing (late April), 1,218,000 inhabitants had downloaded the application, that is about 30 % of the population for which downloading is allowed (age limit 16 years).

However, the number of downloads is not a good metric and there are a few obstacles for making it operable. For instance, the “app” must be installed on the phone, permission to use GPS and Bluetooth must be given, the 4 pages long privacy declaration* has to be accepted, and the battery must provide sufficient power at any time.

The battery issue turns out to be a problem because of GPS-positioning* and the simultaneous use of Bluetooth, which seems necessary to obtain precise location data.

Furthermore, not everyone is accustomed to using the smartphone functionality that is needed, depending of the user interface. For instance elderly people and people with vision impairments* may find it difficult to use the app. And, will the criteria two meters for more than 15 minutes represent a filter that is too coarse to provide useful results and subsequent notification to the user?

For these reasons, the skeptical may wonder if using the app implies that privacy is traded for uncertain and unreliable results from infection tracking.

What the application will provide even if 60% adoption is not realized is data for later research. For instance, data from mobile phone operators who can trace mobile phones movements between base stations could be correlated to instances of infections.

In the name of fighting the pandemic, the main telecommunication companies* are now, with strict privacy considerations, cooperating with The Norwegian Institute of Public Health to analyze movement patterns of the population compared with reported infections. Data is collected in groups of at least 20 people (phones), and identification of individual persons (phones) is not possible*.

Bottom Line

At Runbox we are very concerned about privacy and any type of user tracking that may infringe on this right. While various nations are developing and implementing technological solutions to combat the spread of the decease, we are grateful that we reside in a country with strong privacy traditions. In fact, the first version of personal data protection legislation was implemented in Norway as early as 1978.

It is crucial that The Norwegian Institute of Public Health and The Norwegian Data Protection Authority ensure that the app developers at Simula Research Laboratory (a Norwegian non-profit research organization) attend to both privacy and information security issues in a responsible manner according to the well established tradition in Norway.

When privacy is under threat, as in this case, it is absolutely justified that objections arise. It is often too easy to accept privacy intrusions in the name of a perceived common good.

But one related point could be made as a final remark: Perhaps it would be more appropriate to be concerned about personal data that is collected and shared through one’s use of social media, where personal data is traded and used for purposes that are literally out of control.

* Article unfortunately only available in Norwegian.

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Runbox Email is officially an ethical buy

We are delighted that Ethical Consumer has rated the Runbox email service one of their ethical best buys.

Following a thorough assessment of our business that included areas relating to our privacy policy and whether we were acting in an environmentally friendly way our email service gained one of the highest scores and was given the prestigious title of being an Ethical Consumer Best Buy product (you will need to be a subscriber to see the list of Best Buys and individual email service scores).

We’re obviously very pleased with the outcome of this assessment and it further confirms that our efforts to run a privacy and environmentally conscious service are valued in the wider market of ethical products that consumers seek out.

If you would like to know more about the work that Ethical Consumer do there is information on their website. For more information about the services that Runbox provides please visit runbox.com

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Message from Runbox regarding the global health situation

In situations such as the one we are currently experiencing with COVID-19, uncertainty spreads easily and one may wonder whether services we rely upon will continue to function as usual. We are aware that our email service is of great importance to our customers, and that many rely upon Runbox in their professional and personal lives.

We can assure you that our operations will continue to function normally.

Runbox is located in Norway, a country with robust and reliable Internet services, and the Norwegian government and telecommunication operators are on the alert to ensure that Internet services are running as normal.

In our organization telecommuting is the modus operandi, and we are used to working from home offices or remote locations. For the immediate future the use of our headquarters is suspended in accordance with the advisory from our health authorities, but this will not have any impact on our day-to-day operations.

These are also the regulations our partners in Norway adhere to, and our affiliates abroad will naturally follow the advice in their respective countries. The data center where our servers are located will be enforcing stricter access procedures, but will otherwise operate normally.

This means that maintenance, support, development, and other internal functions will continue to work as usual. Our services are running on our own infrastructure, and there are no indications that our service will be exposed to any consequences of the current situation.

Our mission is to provide electronic communication between people, which is more important than ever in these times. We will continue fulfilling this obligation with dedication and determination.

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Runbox is double carbon negative

As explained in a previous blog post, Runbox works continuously to decrease CO2 emissions from our operations and act in an environmentally responsible manner.

We recently implemented an environmental policy to this end, which lays out our commitments to reducing, reusing, and recycling our resources.

In our policy we also pledge to doubly offset any CO2 emissions that do result from our operations despite our email service being entirely hydropowered.

We are proud to announce that we are now supporting World Land Trust in order to plant trees sufficient to compensate doubly for the emissions that result from our business.

The World Land Trust certificate for carbon dioxide emissions 2019

World Land Trust is an environmental non-profit organization working to ensure conservation of plants, animals and local communities in areas at environmental risk.

We chose World Land Trust after having researched a number of organizations offering similar services, and found World Land Trust to be the most professional and reputable candidate.

We encourage other companies to offset their own emissions in order to help achieve the goal of carbon neutrality.

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GDPR implementation part 8: “Personal data” in the EU and the US is not the same

We usually think of “personal data” as a term that contains for instance a person’s full name, home address, email address, telephone number, and date of birth.

These are ordinary data that can obviously identify a specific person. But in the personal data category of linked personal information are also data such as social security number, passport number, and credit card numbers – data that can identify us, and data we usually feel more restrictive about.

Linkable and non-linkable information

But there is another category of data that on its own may not be able to identify a person, but combined with other information could identify, trace, or locate a person. Such data are gender, race, sexual orientation, workplace, employment etc. These are examples of linkable personal information.

Then we have the category non-personally identifiable information. That is data that cannot be used on its own to identify or trace a person, for example IP addresses, cookies, device IDs, and software IDs (non-linkable personal information).

Privacy regulations differ in the EU and the US

Now, we know that there are industries that exist almost under the radar while taking advantage of personal data. For instance, companies in the AdTech and MarTech industry base their business on collecting and trading personal data for targeted advertising and marketing.

Many of these actors try to take protection of personal data seriously, and refer to the rules and regulations for processing personal data. In Europe this is the GDPR (General Data Protection Regulation) within the EU/EEA-area1, and in the US it is the responsibility of the FTC (Federal Trade Commission).

However, what the EU/GDPR and US government agencies mean by “personal data” is different. Specifically, the definition by EU/GDPR is more comprehensive than the definition often referenced by US agencies, such as that of NIST (National Institute of Technology).

For example, the EU concept of personal data includes information such as cookies and IP addresses, which are not considered as personal data in a US setting.2

This means that if US websites in their privacy policy state that they are GDPR compliant, but combine their data with other data sets, they may breach the GDPR. For example, they must have the user’s consent to collect their IP address under the GDPR.

Definitions of “personal data”

National Institute of Technology’s definition

NIST’s definition of personal data is contained in the definition of Personal Identifiable Information (PII):

PII is any information about an individual maintained by an agency, including (1) any information that can be used to distinguish or trace an individual‘s identity, such as name, social security number, date and place of birth, mother‘s maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.

US Office of Privacy and Open Government’s definition

Another PII-definition is from the US Office of Privacy and Open Government (OPOG) as follows:

The term personally identifiable information refers to information which can be used to distinguish or trace an individual’s identity, such as their name, social security number, biometric records, etc. alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.

EU’s GDPR definition

Compare these PII-definitions with the GDPR Article 4(1)’s definition of personal data:

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

It is obvious that GDPR defines personal data much broader than both NIST’s and OPOG’s PII, and this is underlined by this statement found in GDPR’s Recital 30:

Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

The US is lacking comprehensive regulation

That said, US authorities are moving towards stronger protection of privacy and personal data, but as late as March 2019, the US Congressional Research Service says:

Despite the increased interest in data protection, the legal paradigms governing the security and privacy of personal data are complex and technical, and lack uniformity at the federal level. The Supreme Court has recognized that the Constitution provides various rights protecting individual privacy, but these rights generally guard only against government intrusions and do little to prevent private actors from abusing personal data online. At the federal statutory level, while there are a number of data protection statutes, they primarily regulate certain industries and subcategories of data. The Federal Trade Commission (FTC) fills in some of the statutory gaps by enforcing the federal prohibition against unfair and deceptive data protection practices. But no single federal law comprehensively regulates the collection and use of personal data (our emphasis).

Conclusion

When US websites claim to follow the rules for processing personal data it is dubious at best, compared to the regulations in the EU/EEA – which the Norwegian legislation is based on and is what Runbox adheres to.

However, it should be mentioned that some US states, for instance California, do classify some anonymous data (i.e. IP-addresses, aliases and account data) as PII.

In addition, as stated in our Privacy Policy, the personal data we ask customers to register in order to use our service is very limited. We are conscious about the trust our customers place in us when they register personal data in our systems, and in return we can demonstrate that we are compliant with the regulations.

Addendum

Above we referred to the AdTech and MarTech industries and their usage of personal data to identify, trace, or locate a person for advertising and marketing purposes. That topic is outside the scope of this blog post, but is absolutely worth writing about in a later post.

1 EEA = European Economic Area, that is the EU and three countries: Iceland, Lichtenstein, and Norway.

2 https://www.forbrukerradet.no/out-of-control/ footnote on page 102.

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Our pledge to planet Earth for 2020 and beyond

Cumulative vertebrate species recorded as extinct or extinct in the wild by the IUCN (2012)

We are living at a time unprecedented on Earth.

The year 2019 has confirmed that humanity’s collective activities have pushed Earth’s ecosystems towards the boundaries of what they can sustain.

In fact, for many ecosystems and species the boundary has already been crossed, and species are now vanishing at a rate higher than ever before in recorded history.

The realized threat of global warming

In addition to more obvious drivers of species extinction such as over-exploitation of natural resources and habitat loss caused by agriculture and other land development, the greatest immediate threat to the existing biosphere is global warming.

However, in spite of repeated and increasingly dire warnings from the scientific community for more than a century, greenhouse gas emissions from human activities have increased dramatically and continue to do so.

Already in 1896, Swedish scientist Svante Arrhenius (1859-1927) stated that a doubling of CO2 in the atmosphere would result in a global temperature increase of 5–6°C. Arrhenius’ results are in fact very close to our current climate models.

The benchmark for CO2 content in the atmosphere is the pre-industrial time, that is before about 1750, when the CO2 content is estimated to have been about 280 ppm (parts per million).

Global Atmospheric CO2 since pre-industrial times

By 2017, the annual global average CO2 levels exceeded 400 ppm, which corresponds to the limit of 1.5°C set by the IPCC for keeping the climate changes under safe control. As of November 2019, this number has passed 410 ppm.

Last time the CO2 concentration was that high, horses and camels roamed the high Arctic and sea levels were at least 30 feet higher than today.

The fact that these changes are now happening more rapidly than in recorded history thus far means that many species and ecosystems that make up the biosphere are unable to adapt quickly enough.

A climate spinning out of control

The chemical composition of the atmosphere and the oceans are undergoing dramatic changes with accelerating positive feedback loops involving not only CO2 but methane, nitrogen, and sulfur as well as several other essential components.

These changes are causing the Earth’s biogeochemical cycles, and therefore the climate, to spin out of control.

When the Earth’s temperature increases and its distribution is altered, it affects geophysical systems such as prevailing wind patterns and ocean currents — the global conveyor belt responsible for carrying salt, nutrients, and other essential chemical components upon which marine life depends.

The warmer climate not only melts sea ice and increases sea levels, but heats up wetland peat and thaws tundra in arctic regions which releases additional methane into the atmosphere.

Warmer oceans also absorb less oxygen, which leads to more anaerobic bacteria that produce toxic hydrogen sulfide gases that could have disastrous effects on existing organic life.

These global feedback systems and cycles are so large and complex that it can take decades or centuries for the consequences of our current emissions to take full effect.

This means that we are tipping the balance of the natural systems we depend on for survival and are pushing them to dangerous and unpredictable levels with possibly irreversible effects.

As a result the living Earth itself is turning into an unfamiliar environment that will be detrimental to life as we have known it.

The human race is heading for a disaster — a warned catastrophe, that is — and the entire remaining biosphere is at stake.

The consequences are already upon us

We are ending a year that has seen the most dramatic effects of climate change thus far, closing a decade with increasingly noticeable consequences of continually growing greenhouse gas emissions.

The direct effects are well-known by now and include physical impacts like the melting of ice sheets and subsequent sea level rise, as well as changes in ocean currents and weather patterns.

These impacts in turn lead to increased droughts, heat waves, and uncontrollable wildfires, as well as extreme flooding, cyclones, blizzards, and rainstorms with inevitable crop failures and global fish stock depletion as a result.

In addition to the catastrophic loss of biodiversity, the accelerating changes in our natural environment lead to regional famine, mass migrations, conflicts, and war between peoples fighting for dwindling resources.

Current mitigation plans are inadequate

According to the UN’s Climate Action Summit report we have until 2030 to cut CO2 emissions by 45% in order to limit global warming to 1.5°C . This entails a global average reduction of 4.5% per year over the next 10 years, while emissions on average have increased 1.5% annually in recent years.

This may not sound like much, but in reality it constitutes an enormous challenge on a scale unlike any we have successfully undertaken in the past.

The bottom line is that every person, every organization, every business, and every government have to do their uttermost to reduce their ecological footprint.

Although governments, large industrial companies, and international institutions can do the most to reduce hydrocarbon dependency and restore the depletion of natural resources that is taking place, even small contributions will have an effect — but we are short on time.

Our commitment

At Runbox we have decided to have a positive impact on the planet and our environment, and we want to achieve this with a net negative ecological footprint.

We will take responsibility in several different ways, and have implemented the first version of our Environmental Policy to this end.

In our policy we commit to reducing our ecological footprint as much as possible through reducing, reusing, and recycling the resources we utilize.

This includes our data center, servers and other equipment we acquire, where we source our hardware, how we use and power our office spaces, and the communication and transportation involved in our operations.

For the greenhouse gas emissions that do result from our operations and activities we shall compensate doubly.

We will accomplish this by funding the planting of trees through OneTreePlanted sufficient to absorbing twice the amount of greenhouse gas emissions we are responsible for.

Planting trees is the best existing method of capturing carbon from the atmosphere, and has several other beneficial side-effects as well. So we will support rewilding the forests in order to restore and protect ecosystems, our natural environment, and a habitable climate.

We will also encourage partners, stakeholders, and associates to become more environmentally friendly. Furthermore, we will push for the development and implementation of green and renewable technologies and help encourage governments to become more environmentally responsible.

We are extending our commitment to provide free email services to non-profit organizations with an environmentally oriented profile.

We hope to inspire other companies to adopt similar policies and contribute to a positive impact on the only planet we can call home.

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GDPR implementation part 7: Information and Tools for Implementation of Users’ Rights

GDPR

One of the main objectives for the European Union (EU) when they developed the replacement for the Data Protection Directive 95/46 (from 1995), was to expand individual control over the use of personal data.

This can be seen in a broader view as an implementation of the right to one’s private life, as laid down in the European Convention on Human Rights (Article 8). The right to respect for one’s private and family life is also stated in the EU Treaty on Fundamental Rights (Article 7).

Norway has signed both of these agreements, and the Constitution of Norway implements these rights in Article 100 and 102 of the Constitution and in the Norwegian Human Rights Act.

Already in GDPR1 Article 1 we see the connection between the GDPR and especially the Treaty on Fundamental Rights:

This Regulation protects fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data

Article 1-2 of the GDPR

Observe the expression “rights and freedoms of natural persons“, which is very important throughout the Regulation and is used 31 times in all.

Before we go further into the subject of this post, it is important to state that Norway’s legislation on the processing of personal data was already compliant with the GDPR before the latter was declared as the new framework for the legislation in Norway. The Norwegian Personal Data Act (PDA2), as compliant with the GDPR, tok effect 20 July 2018.

First and foremost, the GDPR states that no processing of personal data shall be done unless the data subject has given consent (Article 6-1, a). Runbox obtains consent to registration of our users’ personal data when they sign up for an account and accept our Terms of Service.

The GDPR (Article 6-1, ff.) allows a controller – that is Runbox in our context – to process personal data when there is a legitimate reason for doing so, i.e. something that is necessary to use our services.

It is an important objective for the GDPR to secure one’s control of one’s own personal data. In this respect, the GDPR has given the data subjects eight fundamental rights (Article 15—17).

When implementing these rights in Runbox, we found that most of those were already there. However, the introduction of the GDPR provided us with a checklist and the opportunity to analyze our status, and to improve our services in this respect.

Our Privacy Policy provides exhaustive information about how we process personal data, but here is an overview of the data subject’s rights, and our implementation of them:

  • The right to access (Article 15): Since Runbox does not collect other types of information than what the users register by themselves, they can easily check which personal data is processed. The data processing is only done in order to process your emails, and optionally your web site and domain name.
  • The right to rectification (Article 16): You may at any time log in to your email account and change your personal information.
  • The right to erasure (‘right to be forgotten’) (Article 17): You may terminate your subscription any time, and your account contents will subsequently be deleted after 6 months. Your personal details data will be deleted after 5 years in accordance with Norwegian accounting regulations. However, you may send a request to dataprotectionofficer@nullrunbox.com for immediate erasure of your account contents.
  • The right to restriction of processing (Article 18): Runbox will never use your personal information for purposes other than providing our services to you, so restrictions are not necessary in our context.
  • The right to be informed (Article 19): Runbox uses your personal information only in order to provide our services to you..
  • The right to data portability (Article 20): In case that you wish to move to another email service provider and export your data, you will find information on how to do this through our services and documentation.
  • The right to object (Article 21): Since we never will use your personal data for other purposes than to deliver the services you have agreed to, this right is implicitly fulfilled.
  • The right to individual decision-making (Article 22): This article is intended to protect data subjects against automated data-processing that might involve profiling them based on personally identifiable information, which is something Runbox doesn’t do.

Regarding questions or concerns about our implementation of the GDPR, customers may use the email address dataprotectionofficer@nullrunbox.com as a direct channel to our appointed Data Protection Officer.

Some final remarks about consent: Runbox uses cookies in order to provide our services, and new users must give express consent to this on our signup page. On this page, and on the Account page once logged in, you may also give/revoke consent to future news and offers from Runbox.

In our next post in this series, we will consider our contractual situation regarding GDPR requirements. Stay tuned.

Footnotes

1. The GDPR means Regulation EU 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC General Data Protection, General Data Processing Regulation. Article refers to Article in the GDPR, unless stated otherwise.

2. The Personal Data Act (the PDA) means the regulations that are currently in force in Norway for the protection of individuals in connection with the processing of personal data, which includes the implementation of GDPR in Norway (2018-07-20).

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