FCM and GDPR

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Nash Zhou

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Mar 15, 2022, 4:33:36 PM3/15/22
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Our app is now using FCM, in order to continue using FCM. We need to know if FCM is now GDPR compliant, and if not, what do we need to do to ensure that we can continue to use FCM under GDPR

Kato Richardson

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Mar 16, 2022, 11:42:57 AM3/16/22
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Hello Nash,


☼, Kato

On Tue, Mar 15, 2022 at 1:33 PM 'Nash Zhou' via Firebase Google Group <fireba...@googlegroups.com> wrote:
Our app is now using FCM, in order to continue using FCM. We need to know if FCM is now GDPR compliant, and if not, what do we need to do to ensure that we can continue to use FCM under GDPR

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Nash Zhou

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Mar 17, 2022, 2:47:48 PM3/17/22
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Hello Kota,
 After reading the privacy guide and data processing and security terms. My understanding is that FCM will collect the user's instanceId. If I delete InstanceId or prohibit the collection of instanceId, does that mean that I am in compliance with GDPR when using FCM? If not, do I need to do further encryption on the data transmitted by FCM to make FCM compliant with GDPR

Kato Richardson

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Mar 18, 2022, 2:25:42 PM3/18/22
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Hello Nash,

I can't tell you what makes you compliant as the data controller; compliance is a complex topic even for legal advisors. I highly recommend consulting one. 

I can tell you that we believe Google is compliant as a data processor, since that's outlined in the privacy doc. We of course have encryption at rest/in transit/et al so that part should be covered.

I don't hear many developers asking about Instance ID in regards to compliance, but I can't say why. Maybe it would help to check out some of the materials in our Play and App Store disclosure guides; they might be enlightening on exactly what info you need to disclose and consider before you track.

☼, Kato



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