Friday, 26 February 2010
Reverse DNS pseudomizer
There's a debate here in Germany about whether an IP address is a piece of data that can (or could) identify a person. This is an important question for the IT industry in Germany because of our stringent data privacy laws: storing and/or processing personal data requires the person's (prior) agreement. The current headlines revolve around Google Analytics but the general question is whether the established procedure of logging IP addresses is in line with the law.
What if IP addresses are declared as personal data? Two questions twirl around in my head:
- What about other uses of IP addresses (like in dynamically generated firewall rules)?
- What's a practical alternative to logging IP addresses?
While my first question is in fact to be taken seriously - albeit it's sort of funny to think about the implications. Hoever, I don't have any further thoughts with respect to question #1. I've seen several academic papers in the past with respect to question #2 but can't currently locate them - with one exception: Ulrich Flegel's paper about pseudomizing Unix log files using a modified syslog daemon (which has additional pseudomizing aspects like unix usernames and the like). My main issue is that the deployment of such a solution would be rather involved for most environments. My (rather easy to deploy) suggestion is a pseudomizing reverse DNS server; the web server would need to be configured to not log IP addresses but rather the reverse DNS name of the visitor (which is a standard configuration option for most servers). However, most webserver admins (understandably) shy away from logging reverse DNS names because of the potential for delays incurred by unsuccessful reverse lookups. However, if a DNS server handling reverse lookups was deployed locally then performance wouldn't be an issue. If this reverse DNS server served not the real reverse DNS name but rather a pseudomized DNS name then all the sudden we would have solved those legal concerns. Well, not quite: of course the IP addreses would need to be stored within the reverse DNS pseudomizer itself; however, I am sure that there are ways to design and operate such a device in that it would be considered compliant to the law (ie: access restricted to a designated privacy officer).
