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deepsuntoday at 6:57 PM1 replyview on HN

If Flock collects and processes PII data, then all their customers are "subprocessors". Flock should really have a Data Processing Agreement with their subprocessors, to legally ensure they follow the same PII handling controls as Flock does.

For example, if Flock receives a legitimate request to delete some data, then Flock must forward that request to all their Data Processors (e.g. including AWS/GCP/Cloudflare) and they must delete it as well.


Replies

Aaargh20318today at 7:00 PM

It’s the other way around. Flock is the subprocessor for whoever hired them to collect data. If they are collecting data on behalf a city or municipality, those are the entities you need to address.