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• Revision 33150 : Essayer de suivre les optimisations de la 2.0.10++ SVN

  23 novembre 2009, par real3t@… — Log

  Essayer de suivre les optimisations de la 2.0.10++ SVN

• LGPD : Demystifying Brazil’s New Data Protection Law

  31 août 2023, par Erin — Privacy

  The General Personal Data Protection Law (LGPD or Lei Geral de Proteção de Dados Pessoais) is a relatively new legislation passed by the Brazilian government in 2018. The law officially took effect on September 18, 2020, but was not enforced until August 1, 2021, due to complications from the COVID-19 pandemic.

  For organisations that do business in Brazil and collect personal data, the LGPD has far-reaching implications, with 65 separate articles that outline how organisations must collect, process, disclose and erase personal data.

  In this article, you’ll learn what the LGPD is, including its contents and how a legal entity can be compliant.

  What is the LGPD ?

  The LGPD is a new data protection and privacy law passed by the Federal Brazilian Government on May 29, 2018. The purpose of the law is to unify the 40 previous Brazilian laws that regulated the processing of personal data.

  

  Many of the older laws have been either updated or removed to accommodate this change. The LGPD comprises 65 separate articles, and each covers a different area of the legislation, such as the rights of data subjects and the legal bases on which personal data may be collected. It also sets out the responsibilities of the National Data Protection Authority (ANPD), a newly created agency responsible for the guidance, supervision and enforcement of the LGPD.

  LGPD compliance is essential for organisations wishing to operate in Brazil and collect personal data for commercial purposes, whether online or offline. However, understanding the different rules and regulations and even figuring out if the LGPD applies to you can be challenging.

  Fortunately, the LGPD is relatively easy to understand and shares many similarities with the General Data Protection Regulation (GDPR), the data protection law implemented on May 25, 2018, by the European Union. This may help you better understand why the LGPD was enacted, the policies it contains and the goals it hopes to achieve. Both laws are very similar, but some items are unique to Brazil, such as what qualifies as a legal basis for collecting personal data.

  For these reasons, organisations should not apply a one-size-fits-all approach to GDPR and LGPD compliance, for they are different laws with different guiding principles and requirements.

  Who does the LGPD apply to, and who is exempt ?

  The LGPD applies to any natural person, public entity and private entity that collects, processes and stores personal data for commercial purposes within the national territory of Brazil. The same also applies to those who process the personal data of Brazilian and non-Brazilian citizens within the national territory of Brazil, even if the data processor is outside of Brazil. It also applies to those who process personal data collected from the national territory of Brazil.

  So, what does this all mean ? 

  Regardless of your location, if you conduct any personal data processing activities in Brazil or you process data that was collected from Brazil, then there is a high possibility that the LGPD applies to you. This is especially true if the data processing is for commercial purposes ; or, to be more precise, for the offering or provision of goods or services. It also means that subjects whose personal data is collected under these conditions are protected by the nine data subject rights.

  There are exceptions where the LGPD does not apply to data processors. These include if you process personal data for private or non-commercial reasons ; for artistic, journalistic and select academic purposes ; and for the purpose of state security, public safety, national defence and activities related to the investigation and prosecution of criminal offenders. Also, if the processed data originates from a country with similar data protection laws to Brazil, such as any country in the European Union (where the GDPR applies), then the LGPD will not apply to that individual or organisation.

  For these reasons, it is vital that you are familiar with the LGPD so that your data processing activities comply with the new standards. This is also important for the future, as an estimated 75% of the global population’s personal data will be protected by a privacy regulation. Getting things right now will make life easier moving forward.

  What are the nine LGPD data subject rights ?

  The LGPD has nine data subject rights. These protect the rights and freedoms of subjects, regardless of their political opinion and religious belief.

  

  These rights, listed under Article 19 of the LGPD, confirm that a data subject has the right to :

  1. Confirm the processing of their data.
  2. Access their data.
  3. Correct data that is incomplete, not accurate and out of date.
  4. Anonymize, block and delete data that is excessive, unnecessary and was not processed in compliance with the law.
  5. Move their data to a different service provider or product provider by special request.
  6. Delete or stop using personal data under certain circumstances.
  7. Gain information about who the data processor has shared the processed data with, including private and public entities.
  8. Be informed as to what the consequences may be for denying consent to the collection of personal data.
  9. Revoke consent to have their personal data processed under certain conditions.

  Many of these data subject rights are like the GDPR. For example, both the GDPR and LGPD give data subjects the right to be informed, the right to access, the right to data portability and the right to rectify false data. However, while the LGPD has nine data subject rights, the GDPR has only eight. What is the extra data subject right ? The right to gain information on who a data processor has shared your data with.

  There are other slight differences between the GDPR and LGPD with regard to data subject rights. For instance, the GDPR has a clear right to restrict certain data processing activities, such as those related to automation. The LGPD has this, too. But the subject of data collection automation is under Article 20, separate from all the data subject rights listed under Article 19.

  Under what conditions can personal data in Brazil be processed ?

  There are various conditions under which organisations can legally conduct personal data processing in Brazil. The aim of these conditions is to give data subjects confidence — that their personal data is processed for only safe, legal and ethical reasons. Also, the conditions help data processors, both individuals and organisations, determine if they have a legal basis for processing personal data in or in relation to Brazil.

  

  According to Article 7 of the LGPD, data processing may only be carried out if done :

  1. With consent by the data subject.
  2. To comply with a legal or regulatory obligation.
  3. By public authorities to assist with the execution of a public policy, one established by law or regulation.
  4. To help research entities carry out studies ; granted, when possible, subjects can anonymize their data.
  5. To carry out a contract or preliminary procedure, in particular, one related to a contract where the data subject is a party.
  6. To exercise the right of an arbitration, administration or judicial procedure.
  7. To protect the physical safety or life of someone
  8. To protect the health of someone about to undergo a procedure performed by health entities
  9. To fulfill the legitimate interests of a data processor, unless doing so would compromise a data subject’s fundamental rights and liberties.
  10. To protect one’s credit score.

  Much like the nine data subject rights, there are key differences between the LGPD and GDPR. The GDPR has six lawful bases for data processing, while the LGPD has ten. One notable addition to the LGPD is for the protection of one’s credit score, which is not covered by the GDPR. Another reason to ensure compliance with both data protection laws separately.

  LGPD vs. GDPR : How do they differ ?

  The LGPD was modeled closely on the GDPR, so it’s no surprise the two are similar. 

  Both laws ensure a high level of protection for the rights and freedoms of data subjects. They outline the legal justifications for data processing, establish the responsibilities of a data protection authority and lay out the penalties for non-compliance. That said, there are key differences between them.

  First, data subject rights ; the LGPD has nine, while the GDPR has eight. The GDPR gives data subjects the right to request a human review of automated decision-making, while the LGPD does not. Second, the legal bases for processing ; the LGPD has ten, while the GDPR has six. The four legal bases unique to the LGPD are : for protection of credit, for protection of health, for protection of life and for research entities carrying out studies.

  Both the LGPD and GDPR have different non-compliance penalties. The maximum fine for an infraction under the GDPR is up to €20 million (or 4% of the offender’s annual global revenue, whichever is higher). The maximum fine for an LGPD infraction is up to 50 million reais (around €9.2 million), or up to 2% of an offender’s revenue in Brazil, whichever is higher.

  6 steps to LGPD compliance with Matomo

  Below are steps you can follow to ensure your organisation is LGPD compliant. You’ll also learn how Matomo can help you comply quickly and easily.

  

  Let’s dive in.

  1. Appoint a DPO

  A DPO is a person, group, or organisation that communicates with data processors, data subjects, and the ANDP.

  Curiously, the LGPD lets you appoint your own DPO — even if they reside out of Brazil. So if the LGPD applies to you, you can appoint someone in your organisation to be a DPO. Just make sure that the nominated person has the understanding and capacity to perform the role’s duties.

  2. Assess your data

  Once you’re familiar with the LGPD and confirm your eligibility for LGPD compliance, take the time to assess your data. If you plan to collect data within the territory of Brazil, you’ll need to confirm the exact location of your data subjects. 

  To do this in Matomo, simply go to the previous year’s calendar. Then click on visitors, go to locations, and look for Brazil under the “Region” section. This will tell you how many of your web visitors are located in Brazil.

  

  3. Review privacy practices

  Review your existing privacy policies and practices, as there’s a good chance they’ll need to be updated to comply with the LGPD. Also, review your data sharing and third-party agreements, as you may need to communicate these new policies to partners that you rely on to deliver your services. 

  Lastly, review your procedures for tracking personal data and Personally Identifiable Information (PII). You may need to modify the type of data that you track to comply with the LGPD. You may even be tracking this data without your knowledge.

  4. Anonymize tracking data

  Data subjects under the LGPD have the right to request data anonymity. Therefore, to be LGPD compliant, your organisation must be able to accommodate for such a request.

  Fortunately, Matomo has various data anonymization techniques that help you protect your data subject’s privacy and comply with the LGPD. These techniques include the ability to anonymize previously tracked raw data, anonymize visitor IP addresses, and anonymize relevant geo-location data such as regions, cities and countries.

  

  You can find these features and more under the Anonymize data tab within the Privacy menu on the Matomo Settings page. Learn more about how to configure privacy settings in Matomo.

  5. Comply with LGPD consent laws without cookies

  By using Matomo to anonymize the data of your data subjects, this enables you to comply with LGPD consent laws and remove the need to display cookie consent banners on your website. This is made possible by the fact that Matomo is a cookieless tracking web analytics platform.

  Unlike other web analytics platforms like Google Analytics, which collect and use third-party cookies (persistent data that remains on your device, until that data expires or until you manually delete it) for their “own purposes,” Matomo is different. We use alternative means to identify web visitors, such as count the number of unique IP addresses and perform browser fingerprinting, neither of which involve the collection of personal data.

  As a result, you don’t have to display cookie consent banners on your website, and you can track your web visitors even if they disable cookies.

  6. Give users the right to opt-out

  Under the LGPD, data subjects have the right to opt-out of your data collection procedures. For this reason, make sure that your web visitors can do this on your website.

  

  You can do this in Matomo by adding an opt-out from tracking form to your website. To do this, click on the cog icon in the top menu, load the settings page, and click on the Users opt-out menu item in the Privacy section. Then follow the instructions to customise and publish the Matomo opt-out form.

  Achieve LGPD compliance with Matomo

  Like GDPR for Europe, the LGPD will impact organisations doing business in Brazil. And while they both share much of the same definitions and data subject rights, they differ on what qualifies as a legal basis for processing sensitive data. Complying with the GDPR and LGPD separately is non-negotiable and essential to avoiding maximum fines of €20 million and €9.2 million, respectively.

  

  As a web analytics platform with LGPD compliance, Matomo prioritises data privacy without compromising performance. Switch to a powerful LGPD-compliant web analytics platform that respects users’ privacy. 

  Get a 21-day free trial of Matomo today. No credit card required.

  Disclaimer

  We are not lawyers and don’t claim to be. The information provided here is to help give an introduction to LGPD. We encourage every business and website to take data privacy seriously and discuss these issues with your lawyer if you have any concerns.

• Developing MobyCAIRO

  26 mai 2021, par Multimedia Mike — General

  I recently published a tool called MobyCAIRO. The ‘CAIRO’ part stands for Computer-Assisted Image ROtation, while the ‘Moby’ prefix refers to its role in helping process artifact image scans to submit to the MobyGames database. The tool is meant to provide an accelerated workflow for rotating and cropping image scans. It works on both Windows and Linux. Hopefully, it can solve similar workflow problems for other people.

  As of this writing, MobyCAIRO has not been tested on Mac OS X yet– I expect some issues there that should be easily solvable if someone cares to test it.

  The rest of this post describes my motivations and how I arrived at the solution.

  Background
  I have scanned well in excess of 2100 images for MobyGames and other purposes in the past 16 years or so. The workflow looks like this :

  
  

  

  Image workflow

  
  

  It should be noted that my original workflow featured me manually rotating the artifact on the scanner bed in order to ensure straightness, because I guess I thought that rotate functions in image editing programs constituted dark, unholy magic or something. So my workflow used to be even more arduous :

  
  

  

  I can’t believe I had the patience to do this for hundreds of scans

  
  

  Sometime last year, I was sitting down to perform some more scanning and found myself dreading the oncoming tedium of straightening and cropping the images. This prompted a pivotal question :

  
  Why can’t a computer do this for me ?
  

  After all, I have always been a huge proponent of making computers handle the most tedious, repetitive, mind-numbing, and error-prone tasks. So I did some web searching to find if there were any solutions that dealt with this. I also consulted with some like-minded folks who have to cope with the same tedious workflow.

  I came up empty-handed. So I endeavored to develop my own solution.

  Problem Statement and Prior Work
  
  I want to develop a workflow that can automatically rotate an image so that it is straight, and also find the most likely crop rectangle, uniformly whitening the area outside of the crop area (in the case of circles).

  As mentioned, I checked to see if any other programs can handle this, starting with my usual workhorse, Photoshop Elements. But I can’t expect the trimmed down version to do everything. I tried to find out if its big brother could handle the task, but couldn’t find a definitive answer on that. Nor could I find any other tools that seem to take an interest in optimizing this particular workflow.

  When I brought this up to some peers, I received some suggestions, including an idea that the venerable GIMP had a feature like this, but I could not find any evidence. Further, I would get responses of “Program XYZ can do image rotation and cropping.” I had to tamp down on the snark to avoid saying “Wow ! An image editor that can perform rotation AND cropping ? What a game-changer !” Rotation and cropping features are table stakes for any halfway competent image editor for the last 25 or so years at least. I am hoping to find or create a program which can lend a bit of programmatic assistance to the task.

  Why can’t other programs handle this ? The answer seems fairly obvious : Image editing tools are general tools and I want a highly customized workflow. It’s not reasonable to expect a turnkey solution to do this.

  Brainstorming An Approach
  I started with the happiest of happy cases— A disc that needed archiving (a marketing/press assets CD-ROM from a video game company, contents described here) which appeared to have some pretty clear straight lines :

  
  
  

  My idea was to try to find straight lines in the image and then rotate the image so that the image is parallel to the horizontal based on the longest single straight line detected.

  I just needed to figure out how to find a straight line inside of an image. Fortunately, I quickly learned that this is very much a solved problem thanks to something called the Hough transform. As a bonus, I read that this is also the tool I would want to use for finding circles, when I got to that part. The nice thing about knowing the formal algorithm to use is being able to find efficient, optimized libraries which already implement it.

  Early Prototype
  A little searching for how to perform a Hough transform in Python led me first to scikit. I was able to rapidly produce a prototype that did some basic image processing. However, running the Hough transform directly on the image and rotating according to the longest line segment discovered turned out not to yield expected results.

  
  
  

  It also took a very long time to chew on the 3300×3300 raw image– certainly longer than I care to wait for an accelerated workflow concept. The key, however, is that you are apparently not supposed to run the Hough transform on a raw image– you need to compute the edges first, and then attempt to determine which edges are ‘straight’. The recommended algorithm for this step is the Canny edge detector. After applying this, I get the expected rotation :

  
  
  

  The algorithm also completes in a few seconds. So this is a good early result and I was feeling pretty confident. But, again– happiest of happy cases. I should also mention at this point that I had originally envisioned a tool that I would simply run against a scanned image and it would automatically/magically make the image straight, followed by a perfect crop.

  Along came my MobyGames comrade Foxhack to disabuse me of the hope of ever developing a fully automated tool. Just try and find a usefully long straight line in this :

  
  

  Darn it, Foxhack…
  

  There are straight edges, to be sure. But my initial brainstorm of rotating according to the longest straight edge looks infeasible. Further, it’s at this point that we start brainstorming that perhaps we could match on ratings badges such as the standard ESRB badges omnipresent on U.S. video games. This gets into feature detection and complicates things.

  This Needs To Be Interactive
  At this point in the effort, I came to terms with the fact that the solution will need to have some element of interactivity. I will also need to get out of my safe Linux haven and figure out how to develop this on a Windows desktop, something I am not experienced with.

  I initially dreamed up an impressive beast of a program written in C++ that leverages Windows desktop GUI frameworks, OpenGL for display and real-time rotation, GPU acceleration for image analysis and processing tricks, and some novel input concepts. I thought GPU acceleration would be crucial since I have a fairly good GPU on my main Windows desktop and I hear that these things are pretty good at image processing.

  I created a list of prototyping tasks on a Trello board and made a decent amount of headway on prototyping all the various pieces that I would need to tie together in order to make this a reality. But it was ultimately slowgoing when you can only grab an hour or 2 here and there to try to get anything done.

  Settling On A Solution
  Recently, I was determined to get a set of old shareware discs archived. I ripped the data a year ago but I was blocked on the scanning task because I knew that would also involve tedious straightening and cropping. So I finally got all the scans done, which was reasonably quick. But I was determined to not manually post-process them.

  This was fairly recent, but I can’t quite recall how I managed to come across the OpenCV library and its Python bindings. OpenCV is an amazing library that provides a significant toolbox for performing image processing tasks. Not only that, it provides “just enough” UI primitives to be able to quickly create a basic GUI for your program, including image display via multiple windows, buttons, and keyboard/mouse input. Furthermore, OpenCV seems to be plenty fast enough to do everything I need in real time, just with (accelerated where appropriate) CPU processing.

  So I went to work porting the ideas from the simple standalone Python/scikit tool. I thought of a refinement to the straight line detector– instead of just finding the longest straight edge, it creates a histogram of 360 rotation angles, and builds a list of lines corresponding to each angle. Then it sorts the angles by cumulative line length and allows the user to iterate through this list, which will hopefully provide the most likely straightened angle up front. Further, the tool allows making fine adjustments by 1/10 of an angle via the keyboard, not the mouse. It does all this while highlighting in red the straight line segments that are parallel to the horizontal axis, per the current candidate angle.

  
  
  

  The tool draws a light-colored grid over the frame to aid the user in visually verifying the straightness of the image. Further, the program has a mode that allows the user to see the algorithm’s detected edges :

  
  
  

  For the cropping phase, the program uses the Hough circle transform in a similar manner, finding the most likely circles (if the image to be processed is supposed to be a circle) and allowing the user to cycle among them while making precise adjustments via the keyboard, again, rather than the mouse.

  
  
  

  Running the Hough circle transform is a significantly more intensive operation than the line transform. When I ran it on a full 3300×3300 image, it ran for a long time. I didn’t let it run longer than a minute before forcibly ending the program. Is this approach unworkable ? Not quite– It turns out that the transform is just as effective when shrinking the image to 400×400, and completes in under 2 seconds on my Core i5 CPU.

  For rectangular cropping, I just settled on using OpenCV’s built-in region-of-interest (ROI) facility. I tried to intelligently find the best candidate rectangle and allow fine adjustments via the keyboard, but I wasn’t having much success, so I took a path of lesser resistance.

  Packaging and Residual Weirdness
  I realized that this tool would be more useful to a broader Windows-using base of digital preservationists if they didn’t have to install Python, establish a virtual environment, and install the prerequisite dependencies. Thus, I made the effort to figure out how to wrap the entire thing up into a monolithic Windows EXE binary. It is available from the project’s Github release page (another thing I figured out for the sake of this project !).

  The binary is pretty heavy, weighing in at a bit over 50 megabytes. You might advise using compression– it IS compressed ! Before I figured out the --onefile command for pyinstaller.exe, the generated dist/ subdirectory was 150 MB. Among other things, there’s a 30 MB FORTRAN BLAS library packaged in !

  Conclusion and Future Directions
  Once I got it all working with a simple tkinter UI up front in order to select between circle and rectangle crop modes, I unleashed the tool on 60 or so scans in bulk, using the Windows forfiles command (another learning experience). I didn’t put a clock on the effort, but it felt faster. Of course, I was livid with proudness the whole time because I was using my own tool. I just wish I had thought of it sooner. But, really, with 2100+ scans under my belt, I’m just getting started– I literally have thousands more artifacts to scan for preservation.

  The tool isn’t perfect, of course. Just tonight, I threw another scan at MobyCAIRO. Just go ahead and try to find straight lines in this specimen :

  
  
  

  I eventually had to use the text left and right of center to line up against the grid with the manual keyboard adjustments. Still, I’m impressed by how these computer vision algorithms can see patterns I can’t, highlighting lines I never would have guessed at.

  I’m eager to play with OpenCV some more, particularly the video processing functions, perhaps even some GPU-accelerated versions.

  The post Developing MobyCAIRO first appeared on Breaking Eggs And Making Omelettes.