I agree with ACN's points, especially the lack of community review and discussion. For example, in section 4.1 on prohibited uses it refers to "Do not break the law", but fails to specify which law, so as written it applies to all laws anywhere enacted by a competent legislative body. Congratulations: it's now a breach of the WMCS ToS to criticise repressive regimes, comparing heads of state to literary figures, and any number of things the suppression of which is in contravention of the movement values. Section 6.2 says "if WMCS administrators fail to reach you within six (6) weeks". That's a pretty onerous time limit for volunteers. Being busy IRL, or in hospital, or… for six weeks is not uncommon and in no way indicates a stable tool is abandoned. Needing to take emergency measures more quickly (like shutting down the VMs) for security issues or the like is an orthogonal concern. 7.2 says Toolforge projects (but not other projects for some reason) must "Use any user agent information … only for the maintenance of your Toolforge Project". Maintenance of the project does not include content negotiation, progressive enhancement, and other functional aspects. Depending on what definition you apply to "user agent information" (since "user agent" is not defined anywhere) this could include authentication headers for e.g. Basic auth, or just the HTTP User-Agent header field, or any information about the user agent (like screen resolution, technical capabilities, supported content types or javascript features). Section 7.3.1 requires all projects that collect personal information to post a privacy policy (and other things). Since section 2 (definitions) defines "user agent" to be personal information equivalent to your password, social security number, real name, and bank account number and information about the user agent is provided to all projects by the anonymising proxy, all projects are by definition collecting personal information. All projects with a web interface are thus required to post a full privacy policy. The definition of "End User" does not exclude the developer / project admin, so all projects without a web interface are also required to post a full privacy policy. If all projects are actually required to post a privacy policy it would be much much simpler to have the policy just say "All projects must post a privacy policy". There is no definition of "collecting" so what technical operations actually constitute "collecting personal information" is unclear. There is no definition of "user agent" so it is unclear whether it is intended to encompass all information provided by the user's User Agent (i.e. web browser), all information _about_ the user's User Agent, or just the content of the User-Agent HTTP header. This also makes the term "user agent information" ambiguous. (Also, please please explain to WMF Legal that the HTTP User-Agent header isn't PII by any reasonable definition. I've tried and failed miserably. This is more-catholic-than-the-pope privacy IMO, and I work with the GDPR in my day job). Deferring a central part of such a policy to a second policy (x-site policy) that does not yet exist and is explicitly still subject to change is akin to writing blank checks or signing a blank contract. It is also quite possibly grounds for invalidating the whole policy as obviously unreasonable in contract law terms. All these things are, from my perspective, fairly problematic, and most of them probably pretty fixable if the community was consulted. That some of them may possibly be harder to fix is not really a good reason to not at least discuss them. Cheers, Xover On Sat, May 27, 2023 at 5:29 AM AntiCompositeNumber < anticompositenumber(a)gmail.com&gt; wrote:

I'm sorry, but that response is unacceptable. The resources of volunteer developers are also limited. Enacting an unclear policy without recent consultation with the groups affected places an unreasonable burden on the volunteers WMCS exists to serve. AntiCompositeNumber (he/him) On Fri, Jun 2, 2023 at 11:45 AM Andrew Bogott &lt;abogott(a)wikimedia.org&gt; wrote: > > Xover, ACN, and others, > > I’m sorry for my slow response – much of the WMCS staff was off for some of this week. > > In 2016 there was an initial public consultation about new terms of use[0]. The fact that we only now have a document to show for it should give you an idea of how difficult this process is. > > I would definitely prefer to have further community review and discussion, but we simply aren't resourced for that. To commit to another round of community review would mean setting this long-needed update aside for more additional years. As I hate to let the perfect be the enemy of the good, I've elected to do what's possible rather than hold out for a process that I do not believe to be possible with current resourcing. > > We may be able to make minor adjustments in wording to the document, but I remain convinced that this document is an improvement over the previous version (among other things, because it has buy-in from legal which the former document lacked). > > That said, I do not mean to entirely stifle discussion on this topic. We need to keep our expectations as low as possible, but I nevertheless encourage those with concerns to comment on the respective talk pages so that we have a record for if/when we have the resources to revise the document. > > -Andrew > > > [0] https://meta.wikimedia.org/wiki/Labs_TOU_Consultation_Round_1_(2016) > > > On 5/27/23 4:39 AM, xover(a)pobox.com wrote: > > I agree with ACN's points, especially the lack of community review and discussion. > > For example, in section 4.1 on prohibited uses it refers to "Do not break the law", but fails to specify which law, so as written it applies to all laws anywhere enacted by a competent legislative body. Congratulations: it's now a breach of the WMCS ToS to criticise repressive regimes, comparing heads of state to literary figures, and any number of things the suppression of which is in contravention of the movement values. > > Section 6.2 says "if WMCS administrators fail to reach you within six (6) weeks". That's a pretty onerous time limit for volunteers. Being busy IRL, or in hospital, or… for six weeks is not uncommon and in no way indicates a stable tool is abandoned. Needing to take emergency measures more quickly (like shutting down the VMs) for security issues or the like is an orthogonal concern. > > 7.2 says Toolforge projects (but not other projects for some reason) must "Use any user agent information … only for the maintenance of your Toolforge Project". Maintenance of the project does not include content negotiation, progressive enhancement, and other functional aspects. Depending on what definition you apply to "user agent information" (since "user agent" is not defined anywhere) this could include authentication headers for e.g. Basic auth, or just the HTTP User-Agent header field, or any information about the user agent (like screen resolution, technical capabilities, supported content types or javascript features). > > Section 7.3.1 requires all projects that collect personal information to post a privacy policy (and other things). Since section 2 (definitions) defines "user agent" to be personal information equivalent to your password, social security number, real name, and bank account number and information about the user agent is provided to all projects by the anonymising proxy, all projects are by definition collecting personal information. All projects with a web interface are thus required to post a full privacy policy. The definition of "End User" does not exclude the developer / project admin, so all projects without a web interface are also required to post a full privacy policy. If all projects are actually required to post a privacy policy it would be much much simpler to have the policy just say "All projects must post a privacy policy". > > There is no definition of "collecting" so what technical operations actually constitute "collecting personal information" is unclear. > > There is no definition of "user agent" so it is unclear whether it is intended to encompass all information provided by the user's User Agent (i.e. web browser), all information _about_ the user's User Agent, or just the content of the User-Agent HTTP header. This also makes the term "user agent information" ambiguous. (Also, please please explain to WMF Legal that the HTTP User-Agent header isn't PII by any reasonable definition. I've tried and failed miserably. This is more-catholic-than-the-pope privacy IMO, and I work with the GDPR in my day job). > > Deferring a central part of such a policy to a second policy (x-site policy) that does not yet exist and is explicitly still subject to change is akin to writing blank checks or signing a blank contract. It is also quite possibly grounds for invalidating the whole policy as obviously unreasonable in contract law terms. > > > All these things are, from my perspective, fairly problematic, and most of them probably pretty fixable if the community was consulted. That some of them may possibly be harder to fix is not really a good reason to not at least discuss them. > > Cheers, > Xover > > > > > On Sat, May 27, 2023 at 5:29 AM AntiCompositeNumber &lt;anticompositenumber(a)gmail.com&gt; wrote: >> >> I am disappointed that these Terms went into effect immediately, >> without any chance for review or comment by the community. This is >> counter to how Wikimedia processes should run, and flies in the face >> of the values of the Wikimedia movement. >> >> I am concerned about some of the provisions of these Terms. For >> example, 7.3 bullet 3 states >> > Not collect any other Personal Information and Wikimedia Usernames from End Users, other than any user agent information forwarded by the anonymizing reverse proxy or OAuth provided usernames and email addresses. >> >> One of my tools, signatures.toolforge.org, provides data on a user's >> signature from their username. The queried username is included in the >> path, and is logged by the default uwsgi logging configuration. It is >> likely that at least some End Users will check their own usernames, so >> therefore the tool is collecting Wikimedia Usernames from End Users. >> >> This *shouldn't* be a violation of the Terms, but by a plain reading >> of them, it is. >> >> I am also concerned that >> https://wikitech.wikimedia.org/wiki/Wikitech:Cloud_Services_Terms_of_use#5.… >> makes reference to a non-existent policy and refers to itself with a >> different title. >> >> I am also disappointed that the revised Terms still require tools to >> be under an OSI-compliant license, without permitting the use of CC-0 >> or public domain grants. The requirement to request and be granted an >> exemption to run one-off scripts without releasing them also seems too >> arduous to be useful. Either free licenses should be required for >> everything, or the approval requirement should be dropped. >> >> The warning at the top should also make clear that developer email >> addresses are public to the Internet, not merely to other WMCS users >> (for example, at <https://ldap.toolforge.org/user/anticomposite>). >> >> The overall layout of the Terms is also confusing, with very short >> sections referring to other very short sections on the other side of >> the document. >> >> AntiCompositeNumber >> (he/him) >> >> On Fri, May 26, 2023 at 9:46 AM Andrew Bogott &lt;abogott(a)wikimedia.org&gt; wrote: >> > >> > After nearly a decade of mishap and delay, we have updated the WMCS >> > terms of use. The updated document for toolforge and cloud-vps admins >> > can be found here: >> > >> > https://wikitech.wikimedia.org/wiki/Wikitech:Cloud_Services_Terms_of_use >> > >> > >> > and the terms of use for visitors to WMCS sites can be found here: >> > >> > https://wikitech.wikimedia.org/wiki/Wikitech:Cloud_Services_End_User_Terms_… >> > >> > >> > There is one significant change in these terms: Cloud-vps projects which >> > collect personal data will need to include an explicit privacy policy >> > for their projects. This is section 7.3. For other WMCS users and admins >> > these documents do not represent any significant change in policy, but >> > do clarify and finalize many things that were poorly-worded in the >> > previous TOU, or policies that we have enforced informally without >> > officially stating. >> > >> > Please feel free to reach out to WMCS staff if you find any part of >> > these documents concerning or disruptive to your work on our platforms. >> > >> > >> > -Andrew >> > >> > >> > >> > >> > >> > >> > _______________________________________________ >> > Cloud-announce mailing list -- cloud-announce(a)lists.wikimedia.org >> > List information: https://lists.wikimedia.org/postorius/lists/cloud-announce.lists.wikimedia.… >> > _______________________________________________ >> > Cloud mailing list -- cloud(a)lists.wikimedia.org >> > List information: https://lists.wikimedia.org/postorius/lists/cloud.lists.wikimedia.org/ >> _______________________________________________ >> Cloud mailing list -- cloud(a)lists.wikimedia.org >> List information: https://lists.wikimedia.org/postorius/lists/cloud.lists.wikimedia.org/ > > > _______________________________________________ > Cloud mailing list -- cloud(a)lists.wikimedia.org > List information: https://lists.wikimedia.org/postorius/lists/cloud.lists.wikimedia.org/ > > > _______________________________________________ > Cloud mailing list -- cloud(a)lists.wikimedia.org > List information: https://lists.wikimedia.org/postorius/lists/cloud.lists.wikimedia.org/

In case it was unclear: I do not intentionally store usernames. The Toolforge infrastructure, in its default configuration, stores usernames. Toolforge also does not provide tools to easily clean up logs. This is not an individual developer problem. AntiCompositeNumber (he/him) On Mon, Jun 5, 2023 at 6:04 PM Maciej Jaros &lt;egil(a)wp.pl&gt; wrote: > > AntiCompositeNumber (2023-05-27 05:29): > > I am disappointed that these Terms went into effect immediately, > > without any chance for review or comment by the community. This is > > counter to how Wikimedia processes should run, and flies in the face > > of the values of the Wikimedia movement. > > > > I am concerned about some of the provisions of these Terms. For > > example, 7.3 bullet 3 states > >> Not collect any other Personal Information and Wikimedia Usernames from End Users, other than any user agent information forwarded by the anonymizing reverse proxy or OAuth provided usernames and email addresses. > > One of my tools, signatures.toolforge.org, provides data on a user's > > signature from their username. The queried username is included in the > > path, and is logged by the default uwsgi logging configuration. It is > > likely that at least some End Users will check their own usernames, so > > therefore the tool is collecting Wikimedia Usernames from End Users. > > > > This *shouldn't* be a violation of the Terms, but by a plain reading > > of them, it is. > > I am not a lawyer, but as a developer with some GDPR experience (EU Law) > -- storing usernames, especially indefinitely, in logs doesn't seem > acceptable to me. You shouldn't store user data you don't need. And if > you store user data, you should allow the user to object and provide a > procedure to delete this data. In general you should probably remove > that data as soon as you do not needed. > > An additional complication could be if you process user data in > conjunction with IP and create some statistics, because then it may fall > under profiling. > > Kind regards, > Nux. > _______________________________________________ > Cloud mailing list -- cloud(a)lists.wikimedia.org > List information: https://lists.wikimedia.org/postorius/lists/cloud.lists.wikimedia.org/