💇🏾 🐊 🔻 How Habr interacts with state bodies and other applicants. Transparency report for all years 🎤 👸🏻 🌃

Hello, Habr! Finally, I am introducing - my name is Alexey Shevelev, and Habré I run the department for ~~combating~~ work with users (which includes fidbek via the feedback form on all projects), simultaneously being a community manager. Sometimes I have to interact with different government services. Today I will tell you how this happens.

Intro. Inbox

As a rule, it all starts with the fact that we receive a request. It can act through four channels:

Call to the office . We do not practice this format of interaction, since it is entirely outside the legal plane and is not regulated by law. Therefore, we politely reject all such appeals and offer to transfer them to the documentary plane, without exception.
. , , . -, , — .
. - — , - - , .
. , . , - , . .

The request must be duly executed. When he arrives, you need to find out whether it is framed as expected.

OK	NOT OK
Made on paper and: Contains handwritten signature; Certified by an original print of the seal; either made in electronic form and: certified by an enhanced qualified electronic signature (corresponding to the signatory); sent from the official email address of the authority. The official e-mail address is provided only in ILV documents, but the requirement for the use of CEP is also established there.	All other requests are not considered proper. Examples: Email Request Email request with a scan of a paper request; Telephone call.

NOT OK

Made on paper and:

Contains handwritten signature;
Certified by an original print of the seal;

either made in electronic form and:

certified by an enhanced qualified electronic signature (corresponding to the signatory);
sent from the official email address of the authority.

The official e-mail address is provided only in ILV documents, but the requirement for the use of CEP is also established there.

All other requests are not considered proper.

Examples:

Email Request
Email request with a scan of a paper request;
Telephone call.

^{Specific examples:

— , «» () , , . ( ) .
— . .
— . , .
— , , , . , info@tmtm.ru , .
— , .}
In larger projects (such as social networks), entire departments are involved in parsing such requests, since the number of calls there is many times larger. We have no more than a couple of such requests per month - a summary table with all requests can be viewed in the updated Transparency report .

Let's go

The law determines the period for which each of the requests must be answered. For example, Roskomnadzor takes three days to hide information prohibited for distribution on the territory of the Russian Federation - if you do not meet the deadline, then sanctions may be applied to the site. In the case of paper requests, the time is longer - up to 30 days. We try not to delay the response, especially when it comes to fraud or violent acts.

Processing of each appeal takes a lot of time, therefore, for convenience, our lawyers drafted a small document with an algorithm of actions in certain situations. To process one request, you need to go through 15 steps and involve from 3 to 4 people (with different powers). The algorithm includes such steps as “scanning the envelope and attachments from all sides”, “inserting a document card in 1C. Document circulation” and “transferring to storage in a pink folder”. The obligatory point at the beginning is to compare the contacts of the department from the network with the contacts on the envelope in order to contact the office and confirm the fact of sending the request.

The main tasks to be solved during any information submission operations are to prevent the issuance of any data in the presence of at least one legal basis for refusal and to limit the amount of information issued to the legislative minimum. As the analysis of query materials showed, the vast majority of them are connected with fraudulent actions by a number of users, mainly on Career and Freelance services.

Guardian of Legal Peace

In addition to the algorithm, the document has template answers for typical stories. So, for example, the most frequent rejection pattern looks like (due to sending the scan by e-mail):

^{By the way, so far only EP has occurred in ILV (and Tax).}

Helpdesk

Appeals through the feedback form from all projects get into our helpdesk (if you want, then we can tell you later how it works). There are several sections in the helpdesk (for each project), all tickets are sorted by them, as well as by the type of call (which the user selects when sending a message). Also in the helpdesk there is a kind of “Address Book”, where, for convenience, the addresses of various departments are added, according to which the rules are also configured. For example, if a letter arrives from @ rkn.gov.ru or colleagues manually add a “Legal” tag for “non-standard” calls to a ticket, then a letter comes to my mail and I plunge into bureaucratic wilds.

The text of the answer, suddenly someone come in handy. Just do not write off verbatim

, №12/3456 24.10.2019 . ( — ), .

.4. . 10, . 10 . 1 . 13 07.02.2011 № 3- « » . 6, . 15 12.0.199 № 144- « - », - , .. - .

- . 6 12.0.199 № 144- « - » .

- . 7 12.0.199 № 144- « - » . , - , - . , №12/3456 24.10.2019 . . .

Then comes the standard work with the ticket: Answer → Mark as resolved. A separate tag allows you to select all calls at any time, for example, for the same Transparency report. Well, or to see that there are no outstanding tickets.

First, all fulfilled requests are added to the internal report, with additional information - who contacted, when, from which mail, to which project and with what request, what was answered, ticket number, etc.

As soon as the request is added to the table with all the necessary information, the tag “Transparency” appears next to the “Legal” tag in the ticket - this is convenient in order to always be able to check whether all of the requests have been recorded in the report.

Transparency report

Our first public report on appeals appeared in September 2018, about which we made a separate publication . Then we ourselves did not understand in what form it is better to do it, but nevertheless decided to inform users that they sometimes contact us, and applicants that their appeal will be known to users. We do not plan to publish the requests ourselves yet, although sometimes we want to - at least by blocking, at least in the form of a line like this: ILV - Blocking of the article “How do LLC pay 133 times less taxes” by decision of the Andropovsky District Court of the Stavropol Territory . But a couple of examples are still considered below.

The report was not only in the form of a publication, but also on a separate page in the reference section. The difficulty was that updating this help section was problematic - until recently, we did not have tools for quick and convenient editing of help information. Because of this, the report ended in 2018, and the correction of any typo or inaccuracy went through seven circles of hell: fat → what to change → what to change → also in the English version → github → test → upload, etc. But there is good news: we are already testing the new WYSIWYG editor and run it right on the admin panel for working with documents and the help section. Soon we will update the information in a matter of minutes.

So, about the report. Information appeared in it for 2019 and 2020, and past periods were replenished with information from other projects - because before such a report was only for Habr, and recently, all projects live under one roof .

In short: in 2020 there were 2 appeals, in 2019 - 14. The most prolific is Roskomnadzor, in second place is the Ministry of Internal Affairs.

Query data for 2019 and 2020

2020


			: 1 ⬝ : 1 ⬝ : 1
			: 1 ⬝ : 1

2019


			: 4 ⬝ : 4 : 1 ⬝ : 1 : 1 ⬝ : 1
			: 1 ⬝ : 1 : 1 ⬝ : 1 : 1 ⬝ : 1 : 2 ⬝ : 1 ⬝ : 1
Google (DMCA)			: 3 ⬝ : 1 ⬝ : 2

: 3,

We are not talking about any mass requests, like on social networks - these are piece stories, which, when studying the context, may seem quite logical.

Examples

The report was replenished with an appeal from 2012 (apparently, it was then that the services were discovered by Habr) - it is the very first and most harmless. “ Is it possible to organize a quick relationship with you on the exchange of information within the legal framework? “- the head of the department on combating cybercrime from a neighboring state asked in a free form.

In general, the Transparency report is not only requests from law enforcement officers, but also any other “official” complaints, for example, from copyright holders. Therefore, it is not entirely correct to read “we received a request” as “t-n major knocked on us”.

Special Service Requests

By the way, I do not remember requests from fellow majors. If the request comes, then it comes from some investigator as part of a criminal case (therefore, we can’t tell the details here). For example, in the case of fraud on Freelansim - yes, as elsewhere: unscrupulous users also come across to us sometimes. But this does not mean at all that we will distribute their data left and right.

^{Signs of a correctly drawn up appeal:

typographic form (not always)
real division of authority
availability of date and number of outgoing. The call center must confirm the number
correctly specified recipient
presence in the request of indication of the basis (case number, KUSP)
description of specific information requested
the presence of contacts of the direct executor. On duty should know this person
print (not always)
( )}
Some requests are rejected due to an incorrect statement and they do not come again. If the request is correctly executed, then almost always they request abstract "registration data" for the account: date / time of registration and last login, phone number (khe) specified during registration, name, etc. - the feeling that they are thoughtlessly copying from a training manual compiled for other projects. In this case, right on the letterhead we print the date / time of registration and last login, mail and the name indicated in the profile, IP addresses - almost everything that in most cases can be seen without us in the user profile. And it’s very rare (it was two or three times) that the user’s “visit logs” are requested for a certain period. In this case, you have to upload data from the server logs and print it in small print.If the user rushed about the site like a wounded saiga, then it's about a pack of paper. Such a document contains only information of the form “data-ip-url”, without the texts of articles, comments, and even more so personal messages. Visually, this reading is somewhat similar to the web server logs. I don’t know how much this helps in the fight against anything / someone, but, as they say, “what kind of TK ...”.

Here is an erroneous request - you can practice searching for errors:

ILV

What infuriates most is the recognition of information forbidden for distribution, that is, a “letter of happiness” from Roskomnadzor. Just a letter arrives: such and such url by the decision of such and such court got into the register of forbidden information, if you don’t hide it, we’ll block it. First you have to execute this order (hide the post or delete the picture), and only then figure out what and why. Each time we examine the context, including to search for the answer "Er, but why?" and almost never find the answer. Mostly, the long-standing posts fall under the distribution, which “long ago made noise” and spread across the network, but which, apparently, were found by some keywords - from “taxes” to “printed a gun on a 3D printer”. Although once ILV still benefited - it banned an account with the name of the casino in the login and seo-spam in the profile,which we would have blocked without court hearings.

We don’t see anything really dangerous or harmful in the list of blocked (at the moment), so we do this:

We contact the authors of the blocked publications and try to provide them with legal assistance in challenging the decision (since they almost always come with violations, for example, without our participation in court hearings). Usually authors are not eager to spend time on this, which is why in the Transparency report opposite to the ILV almost everywhere is “Satisfied” and only a few “Disputed”. In the second case, we had several successful stories - for example, one of them .
We plan to finalize the mechanism for hiding blocked publications, giving an error of 451 in the country that initiated the blocking (so far we have only one country).

Rightholders

For all the time there were only 3 hits - all three from Google (to exclude articles from search results) and all three in one day. For example, about the leak of the source code of Mortal Kombat - it was reported that this is news, and not the source code itself and we were restored (you can google it).

* * *

But there are also unusual cases. For example, once we received a resolution from the FSSP on a property dispute, according to which we were obliged to block the account of one of the users, which the court considered it property. We tried to provide legal assistance, but everything was decided easier - the user started a new account.

Moped is not mine

Or sometimes, from the Ministry of Internal Affairs, requests come to us with a request to provide data on various users of the FriendVokrug service. There are already 5 such requests. We tried to find out the logic of the initiators of requests, but the most intelligible answer was “found on the Internet”. We tried to search - we found a maximum of the Friend Around company card on our career.habr.com service (formerly My Circle), in the basement of which there was contact information for our organization. That's all you need to know ... well, you get the point.

The end

The scale of appeals to us is not as grandiose as those of the same social networks. Largely because all user information is available to everyone, whether it be posts or comments. All interaction is carried out only through official requests, subject to all formalities, without any undocumented and undercover requests. And we don’t see the prerequisites for the growth of quantity, just as we don’t see the need for “ evidence of the canary ” either . On the contrary, we think that with the change of jurisdiction of the legal entity managing Habr, the number of applications will decrease - this is still ahead, wait and see.

* * *

I almost finished this article with an incredible fact - that in the department for working with users (feedback on all projects, moderation of all content) four of the best people work (maroon berets grown on Habré). But he stopped in time, realizing that the story about them deserved a separate post.

How Habr interacts with state bodies and other applicants. Transparency report for all years