├── LICENSE ├── README.md ├── handbook-drafts ├── adding-personal-data-eraser-to-your-plugin.html ├── adding-personal-data-exporter-to-your-plugin.html ├── privacy-related-options-hooks-and-capabilities.html ├── privacy.html └── suggesting-text-for-the-site-privacy-policy.html ├── resources ├── personal-data.md ├── privacy-by-design.md ├── privacy-impact-assessment.md └── protecting-yourself-legally.md └── v1archive ├── Cookies.md ├── Decision Register.md ├── FAQ.md ├── KB.md ├── Privacy-policy-snippets.md ├── Roadmap.md ├── Synched-info.md ├── Trac-Tickets.md ├── Useful-links.md ├── information-resources.md ├── marketing.md ├── shorter-texts.md └── userdocs.md /LICENSE: -------------------------------------------------------------------------------- 1 | GNU GENERAL PUBLIC LICENSE 2 | Version 3, 29 June 2007 3 | 4 | Copyright (C) 2007 Free Software Foundation, Inc. 5 | Everyone is permitted to copy and distribute verbatim copies 6 | of this license document, but changing it is not allowed. 7 | 8 | Preamble 9 | 10 | The GNU General Public License is a free, copyleft license for 11 | software and other kinds of works. 12 | 13 | The licenses for most software and other practical works are designed 14 | to take away your freedom to share and change the works. By contrast, 15 | the GNU General Public License is intended to guarantee your freedom to 16 | share and change all versions of a program--to make sure it remains free 17 | software for all its users. We, the Free Software Foundation, use the 18 | GNU General Public License for most of our software; it applies also to 19 | any other work released this way by its authors. You can apply it to 20 | your programs, too. 21 | 22 | When we speak of free software, we are referring to freedom, not 23 | price. Our General Public Licenses are designed to make sure that you 24 | have the freedom to distribute copies of free software (and charge for 25 | them if you wish), that you receive source code or can get it if you 26 | want it, that you can change the software or use pieces of it in new 27 | free programs, and that you know you can do these things. 28 | 29 | To protect your rights, we need to prevent others from denying you 30 | these rights or asking you to surrender the rights. Therefore, you have 31 | certain responsibilities if you distribute copies of the software, or if 32 | you modify it: responsibilities to respect the freedom of others. 33 | 34 | For example, if you distribute copies of such a program, whether 35 | gratis or for a fee, you must pass on to the recipients the same 36 | freedoms that you received. You must make sure that they, too, receive 37 | or can get the source code. And you must show them these terms so they 38 | know their rights. 39 | 40 | Developers that use the GNU GPL protect your rights with two steps: 41 | (1) assert copyright on the software, and (2) offer you this License 42 | giving you legal permission to copy, distribute and/or modify it. 43 | 44 | For the developers' and authors' protection, the GPL clearly explains 45 | that there is no warranty for this free software. For both users' and 46 | authors' sake, the GPL requires that modified versions be marked as 47 | changed, so that their problems will not be attributed erroneously to 48 | authors of previous versions. 49 | 50 | Some devices are designed to deny users access to install or run 51 | modified versions of the software inside them, although the manufacturer 52 | can do so. This is fundamentally incompatible with the aim of 53 | protecting users' freedom to change the software. The systematic 54 | pattern of such abuse occurs in the area of products for individuals to 55 | use, which is precisely where it is most unacceptable. Therefore, we 56 | have designed this version of the GPL to prohibit the practice for those 57 | products. If such problems arise substantially in other domains, we 58 | stand ready to extend this provision to those domains in future versions 59 | of the GPL, as needed to protect the freedom of users. 60 | 61 | Finally, every program is threatened constantly by software patents. 62 | States should not allow patents to restrict development and use of 63 | software on general-purpose computers, but in those that do, we wish to 64 | avoid the special danger that patents applied to a free program could 65 | make it effectively proprietary. To prevent this, the GPL assures that 66 | patents cannot be used to render the program non-free. 67 | 68 | The precise terms and conditions for copying, distribution and 69 | modification follow. 70 | 71 | TERMS AND CONDITIONS 72 | 73 | 0. Definitions. 74 | 75 | "This License" refers to version 3 of the GNU General Public License. 76 | 77 | "Copyright" also means copyright-like laws that apply to other kinds of 78 | works, such as semiconductor masks. 79 | 80 | "The Program" refers to any copyrightable work licensed under this 81 | License. Each licensee is addressed as "you". "Licensees" and 82 | "recipients" may be individuals or organizations. 83 | 84 | To "modify" a work means to copy from or adapt all or part of the work 85 | in a fashion requiring copyright permission, other than the making of an 86 | exact copy. The resulting work is called a "modified version" of the 87 | earlier work or a work "based on" the earlier work. 88 | 89 | A "covered work" means either the unmodified Program or a work based 90 | on the Program. 91 | 92 | To "propagate" a work means to do anything with it that, without 93 | permission, would make you directly or secondarily liable for 94 | infringement under applicable copyright law, except executing it on a 95 | computer or modifying a private copy. Propagation includes copying, 96 | distribution (with or without modification), making available to the 97 | public, and in some countries other activities as well. 98 | 99 | To "convey" a work means any kind of propagation that enables other 100 | parties to make or receive copies. Mere interaction with a user through 101 | a computer network, with no transfer of a copy, is not conveying. 102 | 103 | An interactive user interface displays "Appropriate Legal Notices" 104 | to the extent that it includes a convenient and prominently visible 105 | feature that (1) displays an appropriate copyright notice, and (2) 106 | tells the user that there is no warranty for the work (except to the 107 | extent that warranties are provided), that licensees may convey the 108 | work under this License, and how to view a copy of this License. If 109 | the interface presents a list of user commands or options, such as a 110 | menu, a prominent item in the list meets this criterion. 111 | 112 | 1. Source Code. 113 | 114 | The "source code" for a work means the preferred form of the work 115 | for making modifications to it. "Object code" means any non-source 116 | form of a work. 117 | 118 | A "Standard Interface" means an interface that either is an official 119 | standard defined by a recognized standards body, or, in the case of 120 | interfaces specified for a particular programming language, one that 121 | is widely used among developers working in that language. 122 | 123 | The "System Libraries" of an executable work include anything, other 124 | than the work as a whole, that (a) is included in the normal form of 125 | packaging a Major Component, but which is not part of that Major 126 | Component, and (b) serves only to enable use of the work with that 127 | Major Component, or to implement a Standard Interface for which an 128 | implementation is available to the public in source code form. A 129 | "Major Component", in this context, means a major essential component 130 | (kernel, window system, and so on) of the specific operating system 131 | (if any) on which the executable work runs, or a compiler used to 132 | produce the work, or an object code interpreter used to run it. 133 | 134 | The "Corresponding Source" for a work in object code form means all 135 | the source code needed to generate, install, and (for an executable 136 | work) run the object code and to modify the work, including scripts to 137 | control those activities. However, it does not include the work's 138 | System Libraries, or general-purpose tools or generally available free 139 | programs which are used unmodified in performing those activities but 140 | which are not part of the work. For example, Corresponding Source 141 | includes interface definition files associated with source files for 142 | the work, and the source code for shared libraries and dynamically 143 | linked subprograms that the work is specifically designed to require, 144 | such as by intimate data communication or control flow between those 145 | subprograms and other parts of the work. 146 | 147 | The Corresponding Source need not include anything that users 148 | can regenerate automatically from other parts of the Corresponding 149 | Source. 150 | 151 | The Corresponding Source for a work in source code form is that 152 | same work. 153 | 154 | 2. Basic Permissions. 155 | 156 | All rights granted under this License are granted for the term of 157 | copyright on the Program, and are irrevocable provided the stated 158 | conditions are met. This License explicitly affirms your unlimited 159 | permission to run the unmodified Program. The output from running a 160 | covered work is covered by this License only if the output, given its 161 | content, constitutes a covered work. This License acknowledges your 162 | rights of fair use or other equivalent, as provided by copyright law. 163 | 164 | You may make, run and propagate covered works that you do not 165 | convey, without conditions so long as your license otherwise remains 166 | in force. You may convey covered works to others for the sole purpose 167 | of having them make modifications exclusively for you, or provide you 168 | with facilities for running those works, provided that you comply with 169 | the terms of this License in conveying all material for which you do 170 | not control copyright. Those thus making or running the covered works 171 | for you must do so exclusively on your behalf, under your direction 172 | and control, on terms that prohibit them from making any copies of 173 | your copyrighted material outside their relationship with you. 174 | 175 | Conveying under any other circumstances is permitted solely under 176 | the conditions stated below. Sublicensing is not allowed; section 10 177 | makes it unnecessary. 178 | 179 | 3. Protecting Users' Legal Rights From Anti-Circumvention Law. 180 | 181 | No covered work shall be deemed part of an effective technological 182 | measure under any applicable law fulfilling obligations under article 183 | 11 of the WIPO copyright treaty adopted on 20 December 1996, or 184 | similar laws prohibiting or restricting circumvention of such 185 | measures. 186 | 187 | When you convey a covered work, you waive any legal power to forbid 188 | circumvention of technological measures to the extent such circumvention 189 | is effected by exercising rights under this License with respect to 190 | the covered work, and you disclaim any intention to limit operation or 191 | modification of the work as a means of enforcing, against the work's 192 | users, your or third parties' legal rights to forbid circumvention of 193 | technological measures. 194 | 195 | 4. Conveying Verbatim Copies. 196 | 197 | You may convey verbatim copies of the Program's source code as you 198 | receive it, in any medium, provided that you conspicuously and 199 | appropriately publish on each copy an appropriate copyright notice; 200 | keep intact all notices stating that this License and any 201 | non-permissive terms added in accord with section 7 apply to the code; 202 | keep intact all notices of the absence of any warranty; and give all 203 | recipients a copy of this License along with the Program. 204 | 205 | You may charge any price or no price for each copy that you convey, 206 | and you may offer support or warranty protection for a fee. 207 | 208 | 5. Conveying Modified Source Versions. 209 | 210 | You may convey a work based on the Program, or the modifications to 211 | produce it from the Program, in the form of source code under the 212 | terms of section 4, provided that you also meet all of these conditions: 213 | 214 | a) The work must carry prominent notices stating that you modified 215 | it, and giving a relevant date. 216 | 217 | b) The work must carry prominent notices stating that it is 218 | released under this License and any conditions added under section 219 | 7. This requirement modifies the requirement in section 4 to 220 | "keep intact all notices". 221 | 222 | c) You must license the entire work, as a whole, under this 223 | License to anyone who comes into possession of a copy. This 224 | License will therefore apply, along with any applicable section 7 225 | additional terms, to the whole of the work, and all its parts, 226 | regardless of how they are packaged. This License gives no 227 | permission to license the work in any other way, but it does not 228 | invalidate such permission if you have separately received it. 229 | 230 | d) If the work has interactive user interfaces, each must display 231 | Appropriate Legal Notices; however, if the Program has interactive 232 | interfaces that do not display Appropriate Legal Notices, your 233 | work need not make them do so. 234 | 235 | A compilation of a covered work with other separate and independent 236 | works, which are not by their nature extensions of the covered work, 237 | and which are not combined with it such as to form a larger program, 238 | in or on a volume of a storage or distribution medium, is called an 239 | "aggregate" if the compilation and its resulting copyright are not 240 | used to limit the access or legal rights of the compilation's users 241 | beyond what the individual works permit. Inclusion of a covered work 242 | in an aggregate does not cause this License to apply to the other 243 | parts of the aggregate. 244 | 245 | 6. Conveying Non-Source Forms. 246 | 247 | You may convey a covered work in object code form under the terms 248 | of sections 4 and 5, provided that you also convey the 249 | machine-readable Corresponding Source under the terms of this License, 250 | in one of these ways: 251 | 252 | a) Convey the object code in, or embodied in, a physical product 253 | (including a physical distribution medium), accompanied by the 254 | Corresponding Source fixed on a durable physical medium 255 | customarily used for software interchange. 256 | 257 | b) Convey the object code in, or embodied in, a physical product 258 | (including a physical distribution medium), accompanied by a 259 | written offer, valid for at least three years and valid for as 260 | long as you offer spare parts or customer support for that product 261 | model, to give anyone who possesses the object code either (1) a 262 | copy of the Corresponding Source for all the software in the 263 | product that is covered by this License, on a durable physical 264 | medium customarily used for software interchange, for a price no 265 | more than your reasonable cost of physically performing this 266 | conveying of source, or (2) access to copy the 267 | Corresponding Source from a network server at no charge. 268 | 269 | c) Convey individual copies of the object code with a copy of the 270 | written offer to provide the Corresponding Source. This 271 | alternative is allowed only occasionally and noncommercially, and 272 | only if you received the object code with such an offer, in accord 273 | with subsection 6b. 274 | 275 | d) Convey the object code by offering access from a designated 276 | place (gratis or for a charge), and offer equivalent access to the 277 | Corresponding Source in the same way through the same place at no 278 | further charge. You need not require recipients to copy the 279 | Corresponding Source along with the object code. If the place to 280 | copy the object code is a network server, the Corresponding Source 281 | may be on a different server (operated by you or a third party) 282 | that supports equivalent copying facilities, provided you maintain 283 | clear directions next to the object code saying where to find the 284 | Corresponding Source. Regardless of what server hosts the 285 | Corresponding Source, you remain obligated to ensure that it is 286 | available for as long as needed to satisfy these requirements. 287 | 288 | e) Convey the object code using peer-to-peer transmission, provided 289 | you inform other peers where the object code and Corresponding 290 | Source of the work are being offered to the general public at no 291 | charge under subsection 6d. 292 | 293 | A separable portion of the object code, whose source code is excluded 294 | from the Corresponding Source as a System Library, need not be 295 | included in conveying the object code work. 296 | 297 | A "User Product" is either (1) a "consumer product", which means any 298 | tangible personal property which is normally used for personal, family, 299 | or household purposes, or (2) anything designed or sold for incorporation 300 | into a dwelling. In determining whether a product is a consumer product, 301 | doubtful cases shall be resolved in favor of coverage. For a particular 302 | product received by a particular user, "normally used" refers to a 303 | typical or common use of that class of product, regardless of the status 304 | of the particular user or of the way in which the particular user 305 | actually uses, or expects or is expected to use, the product. A product 306 | is a consumer product regardless of whether the product has substantial 307 | commercial, industrial or non-consumer uses, unless such uses represent 308 | the only significant mode of use of the product. 309 | 310 | "Installation Information" for a User Product means any methods, 311 | procedures, authorization keys, or other information required to install 312 | and execute modified versions of a covered work in that User Product from 313 | a modified version of its Corresponding Source. The information must 314 | suffice to ensure that the continued functioning of the modified object 315 | code is in no case prevented or interfered with solely because 316 | modification has been made. 317 | 318 | If you convey an object code work under this section in, or with, or 319 | specifically for use in, a User Product, and the conveying occurs as 320 | part of a transaction in which the right of possession and use of the 321 | User Product is transferred to the recipient in perpetuity or for a 322 | fixed term (regardless of how the transaction is characterized), the 323 | Corresponding Source conveyed under this section must be accompanied 324 | by the Installation Information. But this requirement does not apply 325 | if neither you nor any third party retains the ability to install 326 | modified object code on the User Product (for example, the work has 327 | been installed in ROM). 328 | 329 | The requirement to provide Installation Information does not include a 330 | requirement to continue to provide support service, warranty, or updates 331 | for a work that has been modified or installed by the recipient, or for 332 | the User Product in which it has been modified or installed. Access to a 333 | network may be denied when the modification itself materially and 334 | adversely affects the operation of the network or violates the rules and 335 | protocols for communication across the network. 336 | 337 | Corresponding Source conveyed, and Installation Information provided, 338 | in accord with this section must be in a format that is publicly 339 | documented (and with an implementation available to the public in 340 | source code form), and must require no special password or key for 341 | unpacking, reading or copying. 342 | 343 | 7. Additional Terms. 344 | 345 | "Additional permissions" are terms that supplement the terms of this 346 | License by making exceptions from one or more of its conditions. 347 | Additional permissions that are applicable to the entire Program shall 348 | be treated as though they were included in this License, to the extent 349 | that they are valid under applicable law. If additional permissions 350 | apply only to part of the Program, that part may be used separately 351 | under those permissions, but the entire Program remains governed by 352 | this License without regard to the additional permissions. 353 | 354 | When you convey a copy of a covered work, you may at your option 355 | remove any additional permissions from that copy, or from any part of 356 | it. (Additional permissions may be written to require their own 357 | removal in certain cases when you modify the work.) You may place 358 | additional permissions on material, added by you to a covered work, 359 | for which you have or can give appropriate copyright permission. 360 | 361 | Notwithstanding any other provision of this License, for material you 362 | add to a covered work, you may (if authorized by the copyright holders of 363 | that material) supplement the terms of this License with terms: 364 | 365 | a) Disclaiming warranty or limiting liability differently from the 366 | terms of sections 15 and 16 of this License; or 367 | 368 | b) Requiring preservation of specified reasonable legal notices or 369 | author attributions in that material or in the Appropriate Legal 370 | Notices displayed by works containing it; or 371 | 372 | c) Prohibiting misrepresentation of the origin of that material, or 373 | requiring that modified versions of such material be marked in 374 | reasonable ways as different from the original version; or 375 | 376 | d) Limiting the use for publicity purposes of names of licensors or 377 | authors of the material; or 378 | 379 | e) Declining to grant rights under trademark law for use of some 380 | trade names, trademarks, or service marks; or 381 | 382 | f) Requiring indemnification of licensors and authors of that 383 | material by anyone who conveys the material (or modified versions of 384 | it) with contractual assumptions of liability to the recipient, for 385 | any liability that these contractual assumptions directly impose on 386 | those licensors and authors. 387 | 388 | All other non-permissive additional terms are considered "further 389 | restrictions" within the meaning of section 10. If the Program as you 390 | received it, or any part of it, contains a notice stating that it is 391 | governed by this License along with a term that is a further 392 | restriction, you may remove that term. If a license document contains 393 | a further restriction but permits relicensing or conveying under this 394 | License, you may add to a covered work material governed by the terms 395 | of that license document, provided that the further restriction does 396 | not survive such relicensing or conveying. 397 | 398 | If you add terms to a covered work in accord with this section, you 399 | must place, in the relevant source files, a statement of the 400 | additional terms that apply to those files, or a notice indicating 401 | where to find the applicable terms. 402 | 403 | Additional terms, permissive or non-permissive, may be stated in the 404 | form of a separately written license, or stated as exceptions; 405 | the above requirements apply either way. 406 | 407 | 8. Termination. 408 | 409 | You may not propagate or modify a covered work except as expressly 410 | provided under this License. Any attempt otherwise to propagate or 411 | modify it is void, and will automatically terminate your rights under 412 | this License (including any patent licenses granted under the third 413 | paragraph of section 11). 414 | 415 | However, if you cease all violation of this License, then your 416 | license from a particular copyright holder is reinstated (a) 417 | provisionally, unless and until the copyright holder explicitly and 418 | finally terminates your license, and (b) permanently, if the copyright 419 | holder fails to notify you of the violation by some reasonable means 420 | prior to 60 days after the cessation. 421 | 422 | Moreover, your license from a particular copyright holder is 423 | reinstated permanently if the copyright holder notifies you of the 424 | violation by some reasonable means, this is the first time you have 425 | received notice of violation of this License (for any work) from that 426 | copyright holder, and you cure the violation prior to 30 days after 427 | your receipt of the notice. 428 | 429 | Termination of your rights under this section does not terminate the 430 | licenses of parties who have received copies or rights from you under 431 | this License. If your rights have been terminated and not permanently 432 | reinstated, you do not qualify to receive new licenses for the same 433 | material under section 10. 434 | 435 | 9. Acceptance Not Required for Having Copies. 436 | 437 | You are not required to accept this License in order to receive or 438 | run a copy of the Program. Ancillary propagation of a covered work 439 | occurring solely as a consequence of using peer-to-peer transmission 440 | to receive a copy likewise does not require acceptance. However, 441 | nothing other than this License grants you permission to propagate or 442 | modify any covered work. These actions infringe copyright if you do 443 | not accept this License. Therefore, by modifying or propagating a 444 | covered work, you indicate your acceptance of this License to do so. 445 | 446 | 10. Automatic Licensing of Downstream Recipients. 447 | 448 | Each time you convey a covered work, the recipient automatically 449 | receives a license from the original licensors, to run, modify and 450 | propagate that work, subject to this License. You are not responsible 451 | for enforcing compliance by third parties with this License. 452 | 453 | An "entity transaction" is a transaction transferring control of an 454 | organization, or substantially all assets of one, or subdividing an 455 | organization, or merging organizations. If propagation of a covered 456 | work results from an entity transaction, each party to that 457 | transaction who receives a copy of the work also receives whatever 458 | licenses to the work the party's predecessor in interest had or could 459 | give under the previous paragraph, plus a right to possession of the 460 | Corresponding Source of the work from the predecessor in interest, if 461 | the predecessor has it or can get it with reasonable efforts. 462 | 463 | You may not impose any further restrictions on the exercise of the 464 | rights granted or affirmed under this License. For example, you may 465 | not impose a license fee, royalty, or other charge for exercise of 466 | rights granted under this License, and you may not initiate litigation 467 | (including a cross-claim or counterclaim in a lawsuit) alleging that 468 | any patent claim is infringed by making, using, selling, offering for 469 | sale, or importing the Program or any portion of it. 470 | 471 | 11. Patents. 472 | 473 | A "contributor" is a copyright holder who authorizes use under this 474 | License of the Program or a work on which the Program is based. The 475 | work thus licensed is called the contributor's "contributor version". 476 | 477 | A contributor's "essential patent claims" are all patent claims 478 | owned or controlled by the contributor, whether already acquired or 479 | hereafter acquired, that would be infringed by some manner, permitted 480 | by this License, of making, using, or selling its contributor version, 481 | but do not include claims that would be infringed only as a 482 | consequence of further modification of the contributor version. For 483 | purposes of this definition, "control" includes the right to grant 484 | patent sublicenses in a manner consistent with the requirements of 485 | this License. 486 | 487 | Each contributor grants you a non-exclusive, worldwide, royalty-free 488 | patent license under the contributor's essential patent claims, to 489 | make, use, sell, offer for sale, import and otherwise run, modify and 490 | propagate the contents of its contributor version. 491 | 492 | In the following three paragraphs, a "patent license" is any express 493 | agreement or commitment, however denominated, not to enforce a patent 494 | (such as an express permission to practice a patent or covenant not to 495 | sue for patent infringement). To "grant" such a patent license to a 496 | party means to make such an agreement or commitment not to enforce a 497 | patent against the party. 498 | 499 | If you convey a covered work, knowingly relying on a patent license, 500 | and the Corresponding Source of the work is not available for anyone 501 | to copy, free of charge and under the terms of this License, through a 502 | publicly available network server or other readily accessible means, 503 | then you must either (1) cause the Corresponding Source to be so 504 | available, or (2) arrange to deprive yourself of the benefit of the 505 | patent license for this particular work, or (3) arrange, in a manner 506 | consistent with the requirements of this License, to extend the patent 507 | license to downstream recipients. "Knowingly relying" means you have 508 | actual knowledge that, but for the patent license, your conveying the 509 | covered work in a country, or your recipient's use of the covered work 510 | in a country, would infringe one or more identifiable patents in that 511 | country that you have reason to believe are valid. 512 | 513 | If, pursuant to or in connection with a single transaction or 514 | arrangement, you convey, or propagate by procuring conveyance of, a 515 | covered work, and grant a patent license to some of the parties 516 | receiving the covered work authorizing them to use, propagate, modify 517 | or convey a specific copy of the covered work, then the patent license 518 | you grant is automatically extended to all recipients of the covered 519 | work and works based on it. 520 | 521 | A patent license is "discriminatory" if it does not include within 522 | the scope of its coverage, prohibits the exercise of, or is 523 | conditioned on the non-exercise of one or more of the rights that are 524 | specifically granted under this License. You may not convey a covered 525 | work if you are a party to an arrangement with a third party that is 526 | in the business of distributing software, under which you make payment 527 | to the third party based on the extent of your activity of conveying 528 | the work, and under which the third party grants, to any of the 529 | parties who would receive the covered work from you, a discriminatory 530 | patent license (a) in connection with copies of the covered work 531 | conveyed by you (or copies made from those copies), or (b) primarily 532 | for and in connection with specific products or compilations that 533 | contain the covered work, unless you entered into that arrangement, 534 | or that patent license was granted, prior to 28 March 2007. 535 | 536 | Nothing in this License shall be construed as excluding or limiting 537 | any implied license or other defenses to infringement that may 538 | otherwise be available to you under applicable patent law. 539 | 540 | 12. No Surrender of Others' Freedom. 541 | 542 | If conditions are imposed on you (whether by court order, agreement or 543 | otherwise) that contradict the conditions of this License, they do not 544 | excuse you from the conditions of this License. If you cannot convey a 545 | covered work so as to satisfy simultaneously your obligations under this 546 | License and any other pertinent obligations, then as a consequence you may 547 | not convey it at all. For example, if you agree to terms that obligate you 548 | to collect a royalty for further conveying from those to whom you convey 549 | the Program, the only way you could satisfy both those terms and this 550 | License would be to refrain entirely from conveying the Program. 551 | 552 | 13. Use with the GNU Affero General Public License. 553 | 554 | Notwithstanding any other provision of this License, you have 555 | permission to link or combine any covered work with a work licensed 556 | under version 3 of the GNU Affero General Public License into a single 557 | combined work, and to convey the resulting work. The terms of this 558 | License will continue to apply to the part which is the covered work, 559 | but the special requirements of the GNU Affero General Public License, 560 | section 13, concerning interaction through a network will apply to the 561 | combination as such. 562 | 563 | 14. Revised Versions of this License. 564 | 565 | The Free Software Foundation may publish revised and/or new versions of 566 | the GNU General Public License from time to time. Such new versions will 567 | be similar in spirit to the present version, but may differ in detail to 568 | address new problems or concerns. 569 | 570 | Each version is given a distinguishing version number. If the 571 | Program specifies that a certain numbered version of the GNU General 572 | Public License "or any later version" applies to it, you have the 573 | option of following the terms and conditions either of that numbered 574 | version or of any later version published by the Free Software 575 | Foundation. If the Program does not specify a version number of the 576 | GNU General Public License, you may choose any version ever published 577 | by the Free Software Foundation. 578 | 579 | If the Program specifies that a proxy can decide which future 580 | versions of the GNU General Public License can be used, that proxy's 581 | public statement of acceptance of a version permanently authorizes you 582 | to choose that version for the Program. 583 | 584 | Later license versions may give you additional or different 585 | permissions. However, no additional obligations are imposed on any 586 | author or copyright holder as a result of your choosing to follow a 587 | later version. 588 | 589 | 15. Disclaimer of Warranty. 590 | 591 | THERE IS NO WARRANTY FOR THE PROGRAM, TO THE EXTENT PERMITTED BY 592 | APPLICABLE LAW. EXCEPT WHEN OTHERWISE STATED IN WRITING THE COPYRIGHT 593 | HOLDERS AND/OR OTHER PARTIES PROVIDE THE PROGRAM "AS IS" WITHOUT WARRANTY 594 | OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, 595 | THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR 596 | PURPOSE. THE ENTIRE RISK AS TO THE QUALITY AND PERFORMANCE OF THE PROGRAM 597 | IS WITH YOU. SHOULD THE PROGRAM PROVE DEFECTIVE, YOU ASSUME THE COST OF 598 | ALL NECESSARY SERVICING, REPAIR OR CORRECTION. 599 | 600 | 16. Limitation of Liability. 601 | 602 | IN NO EVENT UNLESS REQUIRED BY APPLICABLE LAW OR AGREED TO IN WRITING 603 | WILL ANY COPYRIGHT HOLDER, OR ANY OTHER PARTY WHO MODIFIES AND/OR CONVEYS 604 | THE PROGRAM AS PERMITTED ABOVE, BE LIABLE TO YOU FOR DAMAGES, INCLUDING ANY 605 | GENERAL, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF THE 606 | USE OR INABILITY TO USE THE PROGRAM (INCLUDING BUT NOT LIMITED TO LOSS OF 607 | DATA OR DATA BEING RENDERED INACCURATE OR LOSSES SUSTAINED BY YOU OR THIRD 608 | PARTIES OR A FAILURE OF THE PROGRAM TO OPERATE WITH ANY OTHER PROGRAMS), 609 | EVEN IF SUCH HOLDER OR OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF 610 | SUCH DAMAGES. 611 | 612 | 17. Interpretation of Sections 15 and 16. 613 | 614 | If the disclaimer of warranty and limitation of liability provided 615 | above cannot be given local legal effect according to their terms, 616 | reviewing courts shall apply local law that most closely approximates 617 | an absolute waiver of all civil liability in connection with the 618 | Program, unless a warranty or assumption of liability accompanies a 619 | copy of the Program in return for a fee. 620 | 621 | END OF TERMS AND CONDITIONS 622 | 623 | How to Apply These Terms to Your New Programs 624 | 625 | If you develop a new program, and you want it to be of the greatest 626 | possible use to the public, the best way to achieve this is to make it 627 | free software which everyone can redistribute and change under these terms. 628 | 629 | To do so, attach the following notices to the program. It is safest 630 | to attach them to the start of each source file to most effectively 631 | state the exclusion of warranty; and each file should have at least 632 | the "copyright" line and a pointer to where the full notice is found. 633 | 634 | 635 | Copyright (C) 636 | 637 | This program is free software: you can redistribute it and/or modify 638 | it under the terms of the GNU General Public License as published by 639 | the Free Software Foundation, either version 3 of the License, or 640 | (at your option) any later version. 641 | 642 | This program is distributed in the hope that it will be useful, 643 | but WITHOUT ANY WARRANTY; without even the implied warranty of 644 | MERCHANTABILITY or FITNESS FOR A PARTICULAR PURPOSE. See the 645 | GNU General Public License for more details. 646 | 647 | You should have received a copy of the GNU General Public License 648 | along with this program. If not, see . 649 | 650 | Also add information on how to contact you by electronic and paper mail. 651 | 652 | If the program does terminal interaction, make it output a short 653 | notice like this when it starts in an interactive mode: 654 | 655 | Copyright (C) 656 | This program comes with ABSOLUTELY NO WARRANTY; for details type `show w'. 657 | This is free software, and you are welcome to redistribute it 658 | under certain conditions; type `show c' for details. 659 | 660 | The hypothetical commands `show w' and `show c' should show the appropriate 661 | parts of the General Public License. Of course, your program's commands 662 | might be different; for a GUI interface, you would use an "about box". 663 | 664 | You should also get your employer (if you work as a programmer) or school, 665 | if any, to sign a "copyright disclaimer" for the program, if necessary. 666 | For more information on this, and how to apply and follow the GNU GPL, see 667 | . 668 | 669 | The GNU General Public License does not permit incorporating your program 670 | into proprietary programs. If your program is a subroutine library, you 671 | may consider it more useful to permit linking proprietary applications with 672 | the library. If this is what you want to do, use the GNU Lesser General 673 | Public License instead of this License. But first, please read 674 | . 675 | -------------------------------------------------------------------------------- /README.md: -------------------------------------------------------------------------------- 1 | # Info 2 | 3 | This repository will hold information resources created by the WordPress.org core-privacy team. 4 | 5 | The team's office hours are held on Wednesdays at 1900 UTC in the #core-privacy channel on Making WordPress Slack. 6 | 7 | Bug scrubs are held there as well on Mondays at 1600 UTC. 8 | 9 | ## What we do 10 | 11 | Our 2019 roadmap of work is [here](https://make.wordpress.org/core/roadmap/privacy/). 12 | 13 | We also respond to bugs, privacy concerns, and any related issues as they arise. 14 | 15 | ## Need help? 16 | 17 | The core-privacy team stands ready to assist you. Please message us in the #core-privacy channel on Making WordPress Slack. 18 | 19 | You can also add the "needs-privacy-review" keyword in your Trac tickets. 20 | 21 | ## V1 GDPR 22 | 23 | All documents and resources from the V1 GDPR phase of the core-privacy team's existence (December 2017-May 2018) are archived in the [V1archive folder](https://github.com/wordpress-privacy/info/tree/master/v1archive) for reference. 24 | -------------------------------------------------------------------------------- /handbook-drafts/adding-personal-data-eraser-to-your-plugin.html: -------------------------------------------------------------------------------- 1 | In WordPress 4.9.6, new tools were added to make compliance easier with laws like the European Union's General Data Protection Regulation, or GDPR for short. Among the tools added is a Personal Data Removal tool which supports erasing/anonymizing personal data for a given user. It does NOT delete registered user accounts - that is still a separate step the admin can choose whether or not to do. 2 | 3 | In addition to the personal data stored in things like WordPress comments, plugins can also hook into the eraser feature to erase the personal data they collect, whether it be in something like postmeta or even an entirely new Custom Post Type (CPT). 4 | 5 | Like the exporters, the "key" for all the erasers is the user's email address - this was chosen because it supports erasing personal data for both full-fledged registered users and also unregistered users (e.g. like a logged out commenter). 6 | 7 | However, since performing a personal data erase is a destructive process, we don't want to just do it without confirming the request, so the admin-facing user interface starts all requests by having the admin enter the username or email address making the request and then sends then a link to click to confirm their request. Once a request has been confirmed, the admin can kick off personal data erasure for the user, or force one if the need arises. 8 | 9 | The way the personal data export is erased is similar to how the personal data exporters - and relies on hooking "eraser" callbacks to do the dirty work of erasing the data. When the admin clicks on the remove personal data link, an AJAX loop begins that iterates over all the erasers registered in the system, one at a time. In addition to erasers built into core, plugins can register their own eraser callbacks. 10 | 11 | The eraser callback interface is designed to be as simple as possible. An eraser callback receives the email address we are working with, and a page parameter as well. The page parameter (which starts at 1) is used to avoid plugins potentially causing timeouts by attempting to erase all the personal data they've collected at once. A well behaved plugin will limit the amount of data it attempts to erase per page (e.g. 100 posts, 200 comments, etc.) 12 | 13 | The eraser callback replies whether items containing personal data were erased, whether any items containing personal data were retained, an array of messages to present to the admin (explaining why items that were retained were retained) and whether it is done or not. If an eraser callback reports that it is not done, it will be called again (in a separate request) with the page parameter incremented by 1. 14 | 15 | When all the exporters have been called to completion, the admin user interface is updated to show whether or not all personal data found was erased, and any messages explaining why personal data was retained. 16 | 17 | Let's work on a hypothetical plugin which adds commenter location data to comments. Let's assume the plugin has used `add_comment_meta` to add location data using `meta_key`s of `latitude` and `longitude` 18 | 19 | The first thing the plugin needs to do is to create an eraser function that accepts an email address and a page, e.g.: 20 | 21 | [code] 22 | function my_plugin_eraser( $email_address, $page = 1 ) { 23 | $number = 500; // Limit us to avoid timing out 24 | $page = (int) $page; 25 | 26 | $comments = get_comments( 27 | array( 28 | 'author_email' => $email_address, 29 | 'number' => $number, 30 | 'paged' => $page, 31 | 'order_by' => 'comment_ID', 32 | 'order' => 'ASC', 33 | ) 34 | ); 35 | 36 | $items_removed = false; 37 | 38 | foreach ( (array) $comments as $comment ) { 39 | $latitude = get_comment_meta( $comment->comment_ID, 'latitude', true ); 40 | $longitude = get_comment_meta( $comment->comment_ID, 'longitude', true ); 41 | 42 | if ( ! empty( $latitude ) ) { 43 | delete_comment_meta( $comment->comment_ID, 'latitude' ); 44 | $items_removed = true; 45 | } 46 | 47 | if ( ! empty( $longitude ) ) { 48 | delete_comment_meta( $comment->comment_ID, 'longitude' ); 49 | $items_removed = true; 50 | } 51 | } 52 | 53 | // Tell core if we have more comments to work on still 54 | $done = count( $comments ) < $number; return array( 'items_removed' => $items_removed, 55 | 'items_retained' => false, // always false in this example 56 | 'messages' => array(), // no messages in this example 57 | 'done' => $done, 58 | ); 59 | } 60 | [/code] 61 | 62 | The next thing the plugin needs to do is to register the callback by filtering the eraser array using the `wp_privacy_personal_data_erasers` 63 | filter. 64 | 65 | When registering you provide a friendly name for the eraser (to aid in debugging - this friendly name is not shown to anyone at this time) 66 | and the callback, e.g. 67 | 68 | [code] 69 | function register_my_plugin_eraser( $erasers ) { 70 | $erasers['my-plugin-slug'] = array( 71 | 'eraser_friendly_name' => __( 'Comment Location Plugin' ), 72 | 'callback' => 'my_plugin_eraser', 73 | ); 74 | return $erasers; 75 | } 76 | 77 | add_filter( 78 | 'wp_privacy_personal_data_erasers', 79 | 'register_my_plugin_eraser', 80 | 10 81 | ); 82 | [/code] 83 | 84 | And that's all there is to it! Your plugin will now clean up its personal data! 85 | -------------------------------------------------------------------------------- /handbook-drafts/adding-personal-data-exporter-to-your-plugin.html: -------------------------------------------------------------------------------- 1 |

Background

2 | In WordPress 4.9.6, new tools were added to make compliance easier with laws like the European Union's General Data Protection Regulation, or GDPR for short. Among the tools added is a Personal Data Export tool which supports exporting all the personal data for a given user in a ZIP file. In addition to the personal data stored in things like WordPress comments, plugins can also hook into the exporter feature to export the personal data they collect, whether it be in something like postmeta or even an entirely new Custom Post Type (CPT). 3 | 4 | The "key" for all the exports is the user's email address - this was chosen because it supports exporting personal data for both full-fledged registered users and also unregistered users (e.g. like a logged out commenter). 5 | 6 | However, since assembling a personal data export could be an intensive process and will likely contain sensitive data, we don't want to just generate it and email it to the requestor without confirming the request, so the admin-facing user interface starts all requests by having the admin enter the username or email address making the request and then sends then a link to click to confirm their request. 7 | 8 | Once a request has been confirmed, the admin can generate and download or directly email the personal data export ZIP file for the user, or do the export anyways if the need arises. Inside the ZIP file the user receives, they will find a "mini website" with an index HTML page containing their personal data organized in groups (e.g. a group for comments, etc. ) 9 | 10 | Whether the admin downloads the personal data export ZIP file or sends it directly to the requestor, the way the personal data export is assembled is identical - and relies on hooking "exporter" callbacks to do the dirty work of collecting all the data for the export. When the admin clicks on the download or email link, an AJAX loop begins that iterates over all the exporters registered in the system, one at a time. In addition to exporters built into core, plugins can register their own exporter callbacks. 11 | 12 | The exporter callback interface is designed to be as simple as possible. A exporter callback receives the email address we are working with and a page parameter as well. The page parameter (which starts at 1) is used to avoid plugins potentially causing timeouts by attempting to export all the personal data they've collected at once. A well behaved plugin will limit the amount of data it attempts to erase per page (e.g. 100 posts, 200 comments, etc.) 13 | 14 | The exporter callback replies with whatever data it has for that email address and page and whether it is done or not. If a exporter callback reports that it is not done, it will be called again (in a separate request) with the page parameter incremented by 1. Exporter callbacks are expected to return an array of items for the export. Each item contains an a group identifier for the group of which 15 | the item is a part (e.g. comments, posts, orders, etc.), an optional group label (translated), an item identifier (e.g. comment-133) and then an array of name, value pairs containing the data to be exported for that item. 16 | 17 | It is noteworthy that the value could be a media path, in which case a link to the media file will be added to the index HTML page in the export. 18 | 19 | When all the exporters have been called to completion, WordPress first assembles an "index" HTML document that serves as the heart of the export report. If a plugin reports additional data for an item that WordPress or another plugin has already added, all the data for that item will be presented together. 20 | 21 | Exports are cached on the server for 3 days and then deleted. 22 | 23 | A plugin can register one or more exporters, but most plugins will only need one. Let’s work on a hypothetical plugin which adds location data for the commenter to comments. 24 | 25 | First, let's assume the plugin has used `add_comment_meta` to add location data using `meta_key`s of `latitude` and `longitude` 26 | 27 | The first thing the plugin needs to do is to create an exporter function that accepts an email address and a page, e.g.: 28 | 29 | [code] 30 | function my_plugin_exporter( $email_address, $page = 1 ) { 31 | $number = 500; // Limit us to avoid timing out 32 | $page = (int) $page; 33 | 34 | $export_items = array(); 35 | 36 | $comments = get_comments( 37 | array( 38 | 'author_email' => $email_address, 39 | 'number' => $number, 40 | 'paged' => $page, 41 | 'order_by' => 'comment_ID', 42 | 'order' => 'ASC', 43 | ) 44 | ); 45 | 46 | foreach ( (array) $comments as $comment ) { 47 | $latitude = get_comment_meta( $comment->comment_ID, 'latitude', true ); 48 | $longitude = get_comment_meta( $comment->comment_ID, 'longitude', true ); 49 | 50 | // Only add location data to the export if it is not empty 51 | if ( ! empty( $latitude ) ) { 52 | // Most item IDs should look like postType-postID 53 | // If you don't have a post, comment or other ID to work with, 54 | // use a unique value to avoid having this item's export 55 | // combined in the final report with other items of the same id 56 | $item_id = "comment-{$comment->comment_ID}"; 57 | 58 | // Core group IDs include 'comments', 'posts', etc. 59 | // But you can add your own group IDs as needed 60 | $group_id = 'comments'; 61 | 62 | // Optional group label. Core provides these for core groups. 63 | // If you define your own group, the first exporter to 64 | // include a label will be used as the group label in the 65 | // final exported report 66 | $group_label = __( 'Comments' ); 67 | 68 | // Plugins can add as many items in the item data array as they want 69 | $data = array( 70 | array( 71 | 'name' => __( 'Commenter Latitude' ), 72 | 'value' => $latitude 73 | ), 74 | array( 75 | 'name' => __( 'Commenter Longitude' ), 76 | 'value' => $longitude 77 | ) 78 | ); 79 | 80 | $export_items[] = array( 81 | 'group_id' => $group_id, 82 | 'group_label' => $group_label, 83 | 'item_id' => $item_id, 84 | 'data' => $data, 85 | ); 86 | } 87 | } 88 | 89 | // Tell core if we have more comments to work on still 90 | $done = count( $comments ) < $number; 91 | return array( 92 | 'data' => $export_items, 93 | 'done' => $done, 94 | ); 95 | } 96 | [/code] 97 | 98 | The next thing the plugin needs to do is to register the callback by filtering the exporter array using the `wp_privacy_personal_data_exporters` filter. 99 | 100 | When registering you provide a friendly name for the export (to aid in debugging - this friendly name is not shown to anyone at this time) and the callback, e.g. 101 | 102 | [code] 103 | function register_my_plugin_exporter( $exporters ) { 104 | $exporters['my-plugin-slug'] = array( 105 | 'exporter_friendly_name' => __( 'Comment Location Plugin' ), 106 | 'callback' => 'my_plugin_exporter', 107 | ); 108 | return $exporters; 109 | } 110 | 111 | add_filter( 112 | 'wp_privacy_personal_data_exporters', 113 | 'register_my_plugin_exporter', 114 | 10 115 | ); 116 | [/code] 117 | 118 | And that's all there is to it! Your plugin will now provide data for the export! 119 | -------------------------------------------------------------------------------- /handbook-drafts/privacy-related-options-hooks-and-capabilities.html: -------------------------------------------------------------------------------- 1 |

Options

2 | - wp_page_for_privacy_policy - contains the page ID of a site's privacy page 3 |

Actions

4 | - user_request_action_confirmed - fired when a user confirms a privacy request 5 | - wp_privacy_delete_old_export_files - a scheduled action used to prune old exports from the personal data exports folder 6 | - wp_privacy_personal_data_erased - fired after the last page of the last eraser is complete 7 | - wp_privacy_personal_data_export_file - used to create a personal data export file as part of the export flow 8 | - wp_privacy_personal_data_export_file_created - fires after a personal data export file has been created 9 |

Filters

10 | - user_request_action_confirmed_message - allows modifying the action confirmation message displayed to the user 11 | - wp_privacy_export_expiration - controls how old export files are allowed to get, default is 3 days 12 | - wp_privacy_personal_data_email_content - allows modifying the email message send to users with their personal data export file link 13 | - wp_privacy_personal_data_erasers - supports registration of core and plugin personal data erasers - see also (link to post 37629) 14 | - wp_privacy_personal_data_exporters - supports registration of core and plugin personal data exporters - see also (link to post 37624) 15 |

Capabilities

16 | Access to the privacy tools is controlled by a few new capabilities. These capabilities are: 17 | 18 | - erase_others_personal_data - determines if the Erase Personal Data sub-menu is available under Tools 19 | - export_others_personal_data - determines if the Export Personal Data sub-menu is available under Tools 20 | - manage_privacy_options - determines if the Privacy sub-menu is available under Settings 21 | 22 | Administrators (on non-multisite installations) have these capabilities by default. 23 | -------------------------------------------------------------------------------- /handbook-drafts/privacy.html: -------------------------------------------------------------------------------- 1 | Coming soon. Text being edited here: https://docs.google.com/document/d/1Z2uPgRAcTYB6tBaeVEolawnlPPA4LMuM_NzeNTppTd4/edit# 2 | -------------------------------------------------------------------------------- /handbook-drafts/suggesting-text-for-the-site-privacy-policy.html: -------------------------------------------------------------------------------- 1 | [sub of Privacy] 2 | 3 | Every plugin that collects, uses, or stores user data, or passes it to an external source or third party, should add a section of suggested text to the privacy policy postbox. This is best done with wp_add_privacy_policy_content( $plugin_name, $policy_text ). This will allow site administrators to pull that information into their site's privacy policy. 4 | 5 | To make this simpler for the users, the text should address the questions provided in the default privacy policy: 6 |
    7 |
  • What personal data we collect and why we collect it 8 |
      9 |
    • Their own manually input information
      • 10 |
    • WP: Contact forms
      • 11 |
    • WP: Comments
      • 12 |
    • WP: Cookies
      • 13 |
    • WP: Third party embeds
      • 14 |
    • Analytics
      • 15 |
    16 |
    • 17 |
  • Who we share your data with
    • 18 |
  • How long we retain your data
    • 19 |
  • What rights you have over your data
    • 20 |
  • Where we send your data
    • 21 |
  • Your contact information
    • 22 |
  • How we protect your data
    • 23 |
  • What data breach procedures we have in place
    • 24 |
  • What third parties we receive data from
    • 25 |
  • What automated decision making and/or profiling we do with user data
    • 26 |
  • Any industry regulatory disclosure requirements
    • 27 |
28 |   29 | While not all of these questions will be applicable to all plugins, we recommend taking care with the sections on data sharing. 30 | -------------------------------------------------------------------------------- /resources/personal-data.md: -------------------------------------------------------------------------------- 1 | # What is personal data? 2 | 3 | The European data protection framework pertains to _personal data_. This is defined as “any information relating to an identified or identifiable natural person.” This can be one piece of information or multiple data points combined to create a record. 4 | 5 | Beyond personal data there is also _sensitive personal data_, defined as information about a person’s 6 | 7 | * Racial or ethnic origin 8 | * Political opinions 9 | * Religious or philosophical beliefs 10 | * Trade union membership 11 | * Health data 12 | * Sex life or sexual orientation 13 | * Past or spent criminal convictions 14 | 15 | Sensitive personal data requires stricter protections than regular personal data, and the consequences for its leakage or misuse are greater. 16 | 17 | GDPR expands the definition of personal data to include 18 | 19 | * Genetic data 20 | * Biometric data (such as facial recognition or fingerprint logins) 21 | * Location data 22 | * Pseudonymised data 23 | * Online identifiers 24 | 25 | The latter definition is important for developers. It includes things like IP addresses, mobile device IDs, browser fingerprints, RFID tags, MAC addresses, cookies, telemetry, user account IDs, and any other form of data which is identifiable to a natural person. 26 | 27 | ## Who uses personal data? 28 | Personal data is used by _data controllers_ and _data processors_. The data controller is a person or an entity, such as you or your organisation, which decides what data is collected, how it is used, and whom it is shared with. The data processor is any entity other than the data controller who processes the data on their behalf. 29 | 30 | As a developer, you may be a data controller, you may be a data processor, and you may be both. 31 | 32 | ## Personally Identifiable Information 33 | The European concept of _personal data_ is very different to, and distinct from, the U.S. concept of _personally identifiable information_ (PII), which is defined as "any information about an individual, including any information that can be used to distinguish or trace an individual’s identity, such as name, social security number, date and place of birth, mother’s maiden name, or biometric records; and any other information that is linkable to an individual, such as medical, educational, financial, and employment information." 34 | 35 | _Personal data_ and _personally identifiable information_ are legal definitions which should not be used indistinguishably; for example, a privacy notice targeting European customers should not use the term "PII". 36 | -------------------------------------------------------------------------------- /resources/privacy-by-design.md: -------------------------------------------------------------------------------- 1 | The Privacy by Design (PbD) framework is used to implement privacy as a fundamental value in the development of products and services. 2 | 3 | The framework was [initially developed by Dr Ann Cavoukian in Canada in the 1990s](https://www.ipc.on.ca/wp-content/uploads/Resources/7foundationalprinciples.pdf). 4 | 5 | Under GDPR, developers must demonstrate that they have followed the PbD principles in their project lifecycles. This can be documented in a [Privacy Impact Assessment](https://github.com/wordpress-privacy/info/blob/master/resources/privacy-impact-assessment.md). 6 | 7 | ## The seven PbD Principles 8 | 9 | The framework has seven common-sense principles: 10 | 11 | 1. Privacy must be proactive, not reactive, and must anticipate privacy issues before they reach the user. Privacy must also be preventative, not remedial. 12 | 2. Privacy must be the default setting. The user should not have to take actions to secure their privacy, and consent for data sharing should not be assumed. 13 | 3. Privacy must be embedded into design. It must be a core function of the product or service, not an add-on. 14 | 4. Privacy must be positive sum and should avoid dichotomies. For example, PbD sees an achievable balance between privacy and security, not a zero-sum game of privacy or security. 15 | 5. Privacy must offer end-to-end lifecycle protection of user data. This means engaging in proper data minimization, retention and deletion processes. 16 | 6. Privacy standards must be visible, transparent, open, documented and independently verifiable. Your processes, in other words, must stand up to external scrutiny. 17 | 7. Privacy must be user-centric. This means giving users granular privacy options, maximized privacy defaults, detailed privacy information notices, user-friendly options and clear notification of changes. 18 | 19 | ## Checking your work 20 | 21 | Good PbD practice is about planning and project management, and not just code. The UK's ICO suggests these questions to evaluate you organisation's PbD readiness: 22 | 23 | ☐ We consider data protection issues as part of the design and implementation of systems, services, products and business practices. 24 | 25 | ☐ We make data protection an essential component of the core functionality of our processing systems and services. 26 | 27 | ☐ We anticipate risks and privacy-invasive events before they occur, and take steps to prevent harm to individuals. 28 | 29 | ☐ We only process the personal data that we need for our purposes(s), and that we only use the data for those purposes. 30 | 31 | ☐ We ensure that personal data is automatically protected in any IT system, service, product, and/or business practice, so that individuals should not have to take any specific action to protect their privacy. 32 | 33 | ☐ We provide the identity and contact information of those responsible for data protection both within our organisation and to individuals. 34 | 35 | ☐ We adopt a ‘plain language’ policy for any public documents so that individuals easily understand what we are doing with their personal data. 36 | 37 | ☐ We provide individuals with tools so they can determine how we are using their personal data, and whether our policies are being properly enforced. 38 | 39 | ☐ We offer strong privacy defaults, user-friendly options and controls, and respect user preferences. 40 | 41 | ☐ We only use data processors that provide sufficient guarantees of their technical and organisational measures for data protection by design. 42 | 43 | ☐ When we use other systems, services or products in our processing activities, we make sure that we only use those whose designers and manufacturers take data protection issues into account. 44 | 45 | ☐ We use privacy-enhancing technologies (PETs) to assist us in complying with our data protection by design obligations. 46 | 47 | 48 | Further reading: 49 | - [Introduction to the Privacy by Design framework](https://www.smashingmagazine.com/2017/07/privacy-by-design-framework) 50 | - [Data protection by design and default](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-by-design-and-default/) 51 | -------------------------------------------------------------------------------- /resources/privacy-impact-assessment.md: -------------------------------------------------------------------------------- 1 | # Privacy Impact Assessments 2 | 3 | Privacy Impact Assessments (PIAs) are part of the Privacy by Design (PbD) approach to development. 4 | 5 | A PIA is the process by which questions about data collection, processing, sharing, storage, and access are asked before the work has begun. 6 | 7 | PIAs can also be applied retrospectively to existing projects, and used as a roadmap for fixes and enhancements. 8 | 9 | For data-intensive projects, a PIA document can be requisitioned by a European data protection regulator. 10 | 11 | A PIA is a living document which should be revisited and refreshed as necessary. 12 | 13 | While not all questions will be applicable to all projects, this list approximates a healthy standard: 14 | 15 | ## Data collection and retention 16 | 1. What personal data is processed? 17 | 2. How is that data collected and retained? 18 | 3. Is the data stored locally, on our servers, or both? 19 | 4. For how long is data stored, and when is the data deleted? 20 | 5. Is the data collection and processing specified, explicit, and legitimate? 21 | 6. What is the process for granting consent for the data processing, and is consent explicit and verifiable? 22 | 7. What is the basis of the consent for the data processing? 23 | 8. If not based on consent, what is the legal basis for the data processing? 24 | 9. Is the data minimized to what is explicitly required? 25 | 10. Is the data accurate and kept up to date? 26 | 11. How are users informed about the data processing? 27 | 12. What controls do users have over the data collection and retention? 28 | 29 | ## Technical and security measures 30 | 1. Is the data encrypted? 31 | 2. Is the data anonymized or pseudonymized? 32 | 3. Is the data backed up? 33 | 4. What are the technical and security measures at the host location? 34 | 35 | ## Personnel 36 | 1. Who has access to the data? 37 | 2. What data protection training have those individuals received? 38 | 3. What security measures do those individuals work with? 39 | 4. What data breach notification and alert procedures are in place? 40 | 5. What procedures are in place for government requests? 41 | 42 | ## Subject access rights 43 | 1. How does the data subject exercise their access rights? 44 | 2. How does the data subject exercise their right to data portability? 45 | 3. How does the data subject exercise their rights to erasure and the right to be forgotten? 46 | 4. How does the data subject exercise their right to restrict and object? 47 | 48 | ## Legal 49 | 1. Are the obligations of all data processors, including subcontractors, covered by a contract? 50 | 2. If the data is transferred outside the European Union, what are the protective measures and safeguards? 51 | 52 | ## Risks 53 | 1. What are the risks to the data subjects if the data is misused, mis-accessed, or breached? 54 | 2. What are the risks to the data subjects if the data is modified? 55 | 3. What are the risks to the data subjects if the data is lost? 56 | 4. What are the main sources of risk? 57 | 5. What steps have been taken to mitigate those risks? 58 | -------------------------------------------------------------------------------- /resources/protecting-yourself-legally.md: -------------------------------------------------------------------------------- 1 | ## Tips to protect yourself legally 2 | 3 | While we are not lawyers and cannot issue legal advice, we do have several self-assessment questions which may save you grief down the road. 4 | 5 | - If legally required, are you registered as a data controller with your [national data protection authority](https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en)? 6 | - If legally required, are you registered in international data protection programs such as [Privacy Shield](https://www.privacyshield.gov/welcome)? 7 | - If legally required, have you signed a data processing agreement with your third parties or subprocessors? 8 | - If you capture user data in a service or product, have you determined whether you are legally required to create and document a [Privacy Impact Assessment](https://github.com/wordpress-privacy/info/blob/master/resources/privacy-impact-assessment.md)? 9 | - If you are legally required to create and document a PIA, have you considered [these questions](https://github.com/wordpress-privacy/info/blob/master/resources/privacy-impact-assessment.md)? 10 | - If your plugin's listing mentions legal issues, does your plugin’s description in the repo make explicitly clear that it cannot make a site achieve legal compliance in and of itself? 11 | -------------------------------------------------------------------------------- /v1archive/Cookies.md: -------------------------------------------------------------------------------- 1 | ## Cookies 2 | 3 | Cookies are small pieces of data, contained within text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ’session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by other websites who serve up content on that site (‘third party cookies’). 4 | 5 | ## Cookies set by WordPress.org 6 | 7 | Below the different categories of cookies set by WordPress.org are outlined, with specific examples detailed in the tables that follow. This includes their name and purpose. Certain cookies are only set for logged in visitors, whereas others are set for any visitors, and these are marked below accordingly. Where a cookie only applies to specific subdomains, they are included under the relevant header. 8 | 9 | **Strictly Necessary:** These are the cookies that are essential for WordPress.org to perform basic functions. These include those required to allow registered users to authenticate and perform account related functions. 10 | 11 | **Functionality:** These cookies are used to store preferences set by users such as account name, language, and location. 12 | 13 | **Performance:** Performance cookies collect information on how users interact with websites hosted on WordPress.org, including what pages are visited most, as well as other analytical data. These details are only used to improve how the website functions. 14 | 15 | **Tracking:** These are set by trusted third party networks (e.g. Google Analytics) to track details such as the number of unique visitors, and pageviews to help improve the user experience. 16 | 17 | **Third Party/Embedded Content:** WordPress.org makes use of different third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies. 18 | 19 | ### WordPress.org 20 | 21 | 22 | 23 | 24 | 25 | 26 | 27 | 28 | 29 | 31 | 33 | 34 | 35 | 36 | 37 | 38 | 39 | 40 | 41 | 42 | 43 | 44 | 45 | 46 | 47 | 48 | 49 | 50 | 51 | 52 | 53 | 54 | 55 | 56 | 57 | 58 | 59 | 60 | 61 | 62 | 63 | 64 | 65 | 66 | 67 | 68 | 69 | 70 | 71 | 72 | 73 | 74 | 75 | 76 | 77 | 78 | 79 | 80 | 81 | 82 | 83 | 84 | 85 | 88 | 89 | 90 | 91 | 92 |
CookieDurationPurposeLogged in Users Only?
30 | devicePixelRatio 32 | Browser default (1 year)Used to make the site responsive to the visitor’s screen size.No
wordpress_test_cookieSessionTests that the browser accepts cookies.No
__qca5 yearsQuantcastNo
__utma2 yearsGoogle Analytics - ‘Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.’No
__utmb30 minutesGoogle Analytics - ‘Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.’No
__utmcSessionGoogle Analytics - ‘Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.’No
__utmt10 minutesGoogle Analytics - ‘Used to throttle request rate.’No
__utmz6 monthsGoogle Analytics - ‘Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.’No
wp-settings-{user_id}1 yearUsed to persist a user’s wp-admin configuration.Yes
86 | wporg_logged_in 87 | wporg_sec14 days if you select "Remember Me" when logging in. Otherwise, Session.Used to check whether the current visitor is a logged in WordPress.org user.Yes
93 | 94 | 95 | ### Make.wordpress.org 96 | 97 | 98 | 99 | 100 | 101 | 102 | 103 | 104 | 105 | 107 | 108 | 109 | 110 | 111 | 112 | 114 | 116 | 117 | 119 | 120 |
CookieDurationPurposeLogged in Users Only?
106 | welcome-{blog_id}PermanentUsed to record if you’ve chosen to hidden the "Welcome" message at the top of the corresponding blog.No
113 | showComments 115 | 10 yearsUsed to determine if you prefer comments to be shown or hidden when reading the site. 118 | No
121 | 122 | 123 | ### *.trac.wordpress.org 124 | 125 | 126 | 127 | 128 | 129 | 130 | 131 | 132 | 133 | 135 | 137 | 138 | 140 | 141 |
CookieDurationPurposeLogged in Users Only?
134 | trac_form_token 136 | SessionUsed to check whether the current visitor is a logged in WordPress.org user. 139 | Yes
142 | 143 | 144 | ### Codex.wordpress.org 145 | 146 | 147 | 148 | 149 | 150 | 151 | 152 | 153 | 154 | 158 | 161 | 162 | 165 | 166 | 167 | 169 | 171 | 172 | 174 | 175 | 176 | 178 | 180 | 181 | 183 | 184 |
CookieDurationPurposeLogged in Users Only?
155 | 156 | codexToken 157 | 159 | 160 | 6 monthsUsed to check whether the current visitor is a logged in WordPress.org user. Only set if you select "Keep me logged in" when loggin in. 163 | 164 | Yes
codexUserId 168 | codexUserName 170 | 6 monthsUsed to check whether the current visitor is a logged in WordPress.org user. 173 | Yes
177 | codex_session 179 | SessionUsed to check whether the current visitor is a logged in WordPress.org user. 182 | Yes
185 | 186 | 187 | ## Controlling Cookies 188 | 189 | Visitors may wish to restrict the use of cookies, or completely prevent them from being set. Most browsers provide for ways to control cookie behaviour such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. 190 | 191 | To find out more on how to manage and delete cookies, visit [aboutcookies.org](http://aboutcookies.org/). For more details on advertising cookies, and how to manage them, visit [youronlinechoices.eu](http://www.youronlinechoices.eu/) (EU based), or [aboutads.info](http://www.aboutads.info/choices/) (US based). 192 | 193 | Some specific opt out programs are available here: 194 | 195 | Quantcast - [https://www.quantcast.com/opt-out/](https://www.quantcast.com/opt-out/) 196 | 197 | Google Analytics - [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout) 198 | 199 | It’s important to note that restricting or [disabling](https://www.youtube.com/watch?v=7HrnWC8zBcE) the use of cookies can limit the functionality of sites, or prevent them from working correctly at all. 200 | 201 | 202 | ## Self-hosted WordPress.org site 203 | 204 | Self-hosted WordPress.org sites also use cookies, in core there is a authentication cookie. But also WordPress plugins and themes can set/use cookies, how can we help WordPress users to identify these? 205 | 206 | 207 | 208 | 209 | 210 | 211 | 212 | 213 | 214 | 215 | 216 | 217 | 218 | 219 | 220 | 221 | 222 | 223 | 224 | 225 | 226 | 227 | 228 | 229 | 230 | 231 | 232 | 233 | 234 | 235 | 236 | 237 | 238 | 239 | 240 | 241 | 242 | 243 | 244 | 245 | 246 | 247 | 248 | 249 | 250 | 251 | 252 | 253 | 254 | 255 | 256 | 257 | 258 | 259 | 260 | 261 | 262 | 263 |
ConstantCookieDurationPurposeLogged in Users Only?Links
USER_COOKIE'wordpressuser_' . COOKIEHASHhttps://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L212-L216
PASS_COOKIE'wordpresspass_' . COOKIEHASHhttps://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L218-L222
AUTH_COOKIE'wordpress_' . COOKIEHASH2 daysYeshttps://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L224-L229, https://github.com/WordPress/WordPress/blob/4.9/wp-includes/pluggable.php#L790-L926
SECURE_AUTH_COOKIE'wordpress_sec_' . COOKIEHASHhttps://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L230-L234, https://github.com/WordPress/WordPress/blob/4.9/wp-includes/pluggable.php#L790-L926
LOGGED_IN_COOKIE'wordpress_logged_in_' . COOKIEHASHhttps://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L236-L240
TEST_COOKIE'wordpress_test_cookie'https://github.com/WordPress/WordPress/blob/4.9/wp-includes/default-constants.php#L242-L246
264 | 265 | ### Ideas 266 | 267 | #### User interface 268 | 269 | In the [GDPR plugin](https://github.com/trewknowledge/GDPR) by [Trew Knowledge](https://trewknowledge.com) and @fclaussen WordPress administrators can manually register the cookies used on their site to display a Privacy Policy with all the used cookies. 270 | 271 | #### Cookies API 272 | 273 | There was also a suggestion by @remcotolsma for a WordPres Cookies API so WordPress plugin and theme developers can register the cookies they set/use. This should work in combination with a user interface like the one in the [Trew Knowledge GDPR plugin](https://github.com/trewknowledge/GDPR). 274 | 275 | ```php 276 | wp_register_cookies( 'wordpress', array( 277 | 'label' => __( 'WordPress' ), 278 | 'cookies' => array( 279 | 'wordpress_*' => array( 280 | 'label' => __( 'WordPress Authentication Cookie' ), 281 | 'description' => __( 'This cookie is used for WordPress user authentication.' ), 282 | 'category' => 'required', 283 | 'expiration' => 2 * DAY_IN_SECONDS, 284 | ), 285 | ) ); 286 | 287 | wp_register_cookies( 'woocommerce', array( 288 | 'label' => __( 'WooCommerce', 'woocommerce' ), 289 | 'url' => __( 'https://github.com/woocommerce/woocommerce/blob/3.3.3/includes/class-wc-cart-session.php#L203-L218', 'woocommerce' ), 290 | 'cookies' => array( 291 | 'woocommerce_cart_hash' => array( 292 | 'label' => __( 'WooCommerce Cart Hash', 'woocommerce' ), 293 | 'description' => __( 'This cookie is used to verify the visitors shopping cart.', 'woocommerce' ), 294 | 'category' => 'required', 295 | 'expiration' => HOUR_IN_SECONDS, 296 | ), 297 | 'woocommerce_items_in_cart' => array( 298 | 'label' => __( 'WooCommerce Number Items in Cart', 'woocommerce' ), 299 | 'description' => __( 'This cookie is used to keep track of the number of items in the visitors shopping cart.', 'woocommerce' ), 300 | 'category' => 'required', 301 | 'expiration' => HOUR_IN_SECONDS, 302 | ), 303 | 'wp_woocommerce_session_*' => array( 304 | 'label' => __( 'WooCommerce Session ID', 'woocommerce' ), 305 | 'description' => __( 'This cookie is used to keep track of visitors session.', 'woocommerce' ), 306 | 'category' => 'required', 307 | 'expiration' => 48 * HOUR_IN_SECONDS, 308 | ), 309 | ), 310 | ) ); 311 | 312 | wp_register_cookies( 'google-analytics-for-wordpress', array( 313 | 'label' => __( 'MonsterInsights - Google Analytics', 'google-analytics-for-wordpress' ), 314 | 'url' => __( 'https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage', ) 315 | 'cookies' => array( 316 | '_ga' => array( 317 | 'label' => __( '_ga', 'google-analytics-for-wordpress' ), 318 | 'description' => __( 'Used to distinguish users.', 'google-analytics-for-wordpress' ), 319 | 'category' => 'analytics', 320 | 'expiration' => 2 * YEAR_IN_SECONDS, 321 | ), 322 | '_gid' => array( 323 | 'label' => __( '_gid', 'google-analytics-for-wordpress' ), 324 | 'description' => __( 'Used to distinguish users.', 'google-analytics-for-wordpress' ), 325 | 'category' => 'analytics', 326 | 'expiration' => 24 * HOUR_IN_SECONDS, 327 | ), 328 | '_gat' => array( 329 | 'label' => __( '_gat', 'google-analytics-for-wordpress' ), 330 | 'description' => __( 'Used to throttle request rate.', 'google-analytics-for-wordpress' ), 331 | 'category' => 'analytics', 332 | 'expiration' => array( 333 | 'from' => 30, 334 | 'to' => YEAR_IN_SECONDS, 335 | ), 336 | ), 337 | '_gac_*' => array( 338 | 'label' => __( '_gac_', 'google-analytics-for-wordpress' ), 339 | 'description' => __( 'Contains campaign related information for the user.', 'google-analytics-for-wordpress' ), 340 | 'category' => 'analytics', 341 | 'expiration' => 90 * DAY_IN_SECONDS, 342 | ), 343 | ), 344 | ) ); 345 | ``` 346 | -------------------------------------------------------------------------------- /v1archive/Decision Register.md: -------------------------------------------------------------------------------- 1 | | Request | Comments | Decision | Status | 2 | | ------- | -------- | -------- | ------ | 3 | | Are WP posts "personal data" (keeping in mind that they may be authored by several people) | It depends. One of the earliest pieces of case law on European data protection law, from the 1990s, was about gossip on a church web site which was ruled to be personal data which violated someone's privacy even though maybe ten people saw the page and five of those were the legal team | | Open | 4 | | Can WP registered users be considered "controllers" of the data they control. For example all admins can control all aspects of a site. All editors can edit any content, all authors can edit their own posts and comments. Are admins, editors and authors "controllers" in GDPR terms? | That would depend entirely on user access levels. Take the recent Carphone Warehouse breach, where 30-odd people were given Admin access to everything from employees' HR information to customers' credit card numbers. Most of them did not need to be admins and certainly should not have been. So the user role is less important than what data they access and what they do with it. In general admins are absolutely controllers. Editors and authors would depend. | | Open | 5 | |Should we always export post content as part of a request?| Should we treat post (content) as potential Personal Data - if a user requests his data, for possible erasure. Would also exporting posts that he has created( is owner of), or is mentioned in (e-mail or name mentioned in the content) be Personal Data? || Open | 6 | -------------------------------------------------------------------------------- /v1archive/FAQ.md: -------------------------------------------------------------------------------- 1 | # FAQ - Frequently Asked Questions 2 | 3 | ## How can I help? 4 | 5 | You want to help the team in getting ready for GDPR? Great! Some places to start: 6 | * Check the roadmap on [https://github.com/gdpr-compliance/info/blob/master/Roadmap.md](https://github.com/gdpr-compliance/info/blob/master/Roadmap.md) 7 | * Look at the Trac tickets on [https://core.trac.wordpress.org/query?status=!closed&keywords=~gdpr](https://core.trac.wordpress.org/query?status=!closed&keywords=~gdpr) and see where you can help with patching or give your comments. 8 | * Help update information on our (temporary) GitHub repository on [https://github.com/gdpr-compliance/info](https://github.com/gdpr-compliance/info). Just propose your changes and somebody will evaluate and add them. 9 | * And last but not least, let the world know! The more you tweet, post or share, the more people that can join and help us bring WordPress to a correct GDPR level. 10 | 11 | ## What personal information available for the user in that 3rd party service should we mention on the site's GDPR Privacy Notice? 12 | 13 | ## A user asks me to anonymise his personal data, including Stripe/Paypal. What can I do? 14 | 15 | -------------------------------------------------------------------------------- /v1archive/KB.md: -------------------------------------------------------------------------------- 1 | # Knowledge Base 2 | 3 | ## What is personal data (@webdevlaw) 4 | The European data protection framework pertains to personal data. This is defined as “any information relating to an identified or identifiable natural person.” This can be one piece of information or multiple data points combined to create a record. 5 | 6 | Beyond personal data there is also sensitive personal data, defined as information about a person’s 7 | 8 | * Racial or ethnic origin 9 | * Political opinions 10 | * Religious or philosophical beliefs 11 | * Trade union membership 12 | * Health data 13 | * Sex life or sexual orientation 14 | * Past or spent criminal convictions 15 | 16 | Sensitive personal data requires stricter protections than regular personal data, and the consequences for its leakage or misuse are greater. 17 | 18 | GDPR expands the definition of personal data to include 19 | 20 | * Genetic data 21 | * Biometric data (such as facial recognition or fingerprint logins) 22 | * Location data 23 | * Pseudonymised data 24 | * Online identifiers 25 | 26 | The latter definition is important for developers. It includes things like IP addresses, mobile device IDs, browser fingerprints, RFID tags, MAC addresses, cookies, telemetry, user account IDs, and any other form of data which is identifiable to a natural person. 27 | 28 | The European term “personal data” differs from the American term “personally identifiable information.” The latter pertains to a much more limited set of information than the European model. It also does not see information as contextual, whereas the European framework emphasises the risks inherent in data aggregation. 29 | 30 | Personal data is used by data controllers and data processors. The data controller is a person or an entity, such as you or your organisation, which decides what data is collected, how it is used, and whom it is shared with. The data processor is any entity other than the data controller who processes the data on their behalf. As a developer, you may be a data controller, you may be a data processor, and you may be both. 31 | 32 | ## What Personal Data do we find in Core (To Be Updated!) 33 | The following data has to be considered for anonymising, deleting, etc: 34 | 1. For Users 35 | 36 | * User Login 37 | * User Pass 38 | * User Nicename 39 | * User Display Name 40 | * User Email 41 | * User URL 42 | 43 | 1. For Comments 44 | 45 | * Author name 46 | * Author email 47 | * Author IP 48 | * Author URL 49 | * Author user agent 50 | 51 | What is NOT considered to be anonymised (so only the above parts are needed): 52 | * Posts/comments : Once a user is anynomised, the post/comment cannot be linked to the user anymore so should not be further anonymised. 53 | 54 | ## How do others allow users to download their own data 55 | 1. Facebook 56 | 57 | * https://www.facebook.com/settings 58 | * At the bottom click on 'Download a copy of your facebook data' 59 | * What is included? 60 | + Posts, photos and videos you've shared 61 | + Your messages and chat conversations 62 | + Info from the About section of your Profile 63 | + See full list on https://www.facebook.com/help/405183566203254 64 | * Check also facebook ads: https://www.facebook.com/ads/preferences/ 65 | 66 | 2. Twitter 67 | 68 | * https://twitter.com/settings/your_twitter_data 69 | * Re-enter your password 70 | * Find the list of what data is kept 71 | * At the bottom 'Request your data' to get it by email 72 | 73 | 3. Google 74 | 75 | * https://takeout.google.com/settings/takeout 76 | -------------------------------------------------------------------------------- /v1archive/Privacy-policy-snippets.md: -------------------------------------------------------------------------------- 1 | # Privacy Policy Snippets 2 | 3 | Copy and paste-able snippets that describe how core collects, manages and shares data provided by site users and visitors. 4 | 5 | ## Definitions 6 | 7 | * Logged In vs Logged Out Users: Logged in users are users who have registered (created) an account on the site and have provided their Username and password to log in to the site. Some sites require users to be registered and logged in to do things like comment on an article. Logged out users are users who have not logged in, or who do not have an account on the site at all (e.g. visitors). 8 | * Gravatar: An optional public profile, including a photo or image, related to your Email Address. 9 | * IP Address: The address of your device on the Internet. This address is assigned by the Internet Service Provider providing the connection to the Internet which your device is using and may be shared with other devices at that same location. 10 | * REST API: An alternative means of accessing the data on a website. Instead of navigating a browser to a page to retrieve website content, a script or other means is used to electronically collect website content. The content retrieved via the REST API interface for a given article or media attachment may include more data than is displayed in a browser. 11 | * Role: A logged in user also has a role, e.g. Contributor, Author, Editor, etc. Each role has a prescribed set of capabilities - e.g. some roles can delete comments but others cannot. 12 | * User Agent: A browser’s user agent is a line of text that usually includes which browser you are using, its version, and your operating system and its version. 13 | 14 | ## Cookies 15 | 16 | * If you are logged out and leave a comment on this site you may opt-in to saving your name, email address and website. If you opt-in, three cookies will be created - one for your name, one for your email address and one for your website. These cookies are unique to this site and will persist for 1 year. `(comment_author_{site}, comment_author_email_{site}, comment_author_url_{site})` 17 | 18 | * If you attempt to log in to this site, we will set a temporary cookie to determine if your browser accepts cookies at all. This cookie contains no personal data and is discarded when you close your browser. `(wordpress_test_cookie)` 19 | 20 | * If you have an account and you log in to this site, we will set up to three cookies to save your log in information in your browser. These cookies are unique to this site and include your user name and a login token for you. If you select “Remember Me” these cookies will persist for two weeks. If not, they will persist for two days. Since these cookies save your user name and login information, if you log into this site using a public computer, it is important to log out before leaving the computer to prevent unauthorized access. `(wordpress_{site}, wordpress_sec_{site}, wordpress_logged_in_{site}).` 21 | 22 | * If you have an account, if your role permits it and if you use the administration pages of this site, up to two additional cookies will be saved in your browser. These cookies both include your user ID. The first cookie contains any screen options you've selected and the second contains the timestamp of the last time you visited an administration page. They expire after 1 year. `(wp-settings-{userID}, wp-settings-time-{userID})` 23 | 24 | * If you have an account, if your role permits it and if you use the administration pages of this site to edit articles, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day. `(wp-saving-post)` 25 | 26 | ## Comments 27 | 28 | ### Comments Left by All Users 29 | 30 | * If you elect to leave a comment on an article, in addition to the comment text you provide we also collect your IP Address and your User Agent. 31 | * Your comment text, your Name, Email Address, Website (URL), IP Address and User Agent are accessible by administrators on our site. 32 | * An anonymized string created from your Email Address (also called a hash) is provided to the Gravatar service to see if a profile picture of you is available for display. The Gravatar service privacy policy is available here: https://automattic.com/privacy/ Prior to approval of your comment, your profile picture is only visible to administrators. After approval of your comment, your profile picture is visible to the public in the context of your comment. 33 | * Following approval of your comment, your comment text, your Name, and Website (URL) (if provided) are visible to the public. 34 | * Comments containing links or certain words or phrases may require manual approval by an administrator. 35 | * Your comment, including comment text, your Name, Email Address, Website (URL), IP Address and User Agent, is: 36 | * shared with the Akismet service to determine whether or not your comment is spam. The Akismet service privacy policy is available here: https://automattic.com/privacy/ 37 | * stored in the website’s database, access to which is restricted to site administrators. Site administrator authentication is by username and password. 38 | * retained indefinitely until explicitly deleted by an administrator. 39 | 40 | ### Comments Left by Logged In Users 41 | 42 | * You may edit the Display Name used for new comments in your profile. 43 | * If your role on the site has sufficient permission (e.g. Editor), you may edit or delete comments. 44 | 45 | ### Comments Left by Logged Out Users / Visitors 46 | 47 | * If you are not logged in to the site and elect to leave a comment on an article, we require your Name and your Email Address and we request your Website (URL). You may also elect to provide a partial name, initials or even a pseudonym in lieu of your full name. You are not required to provide a website URL. 48 | * When you leave a comment, you will be asked if you opt-in to saving your Name, Email Address and Website (URL) in your browser for future commenting. If you so opt-in, we store three cookies on your browser to make it easier for you to comment again in the future. The cookies contain your Name, your Email Address and your Website (URL). They are set to expire after one year. 49 | 50 | ## Embedded Content 51 | 52 | * Articles on this site may include embedded content from other services (e.g. videos, images, articles, etc.). 53 | * These services may collect your IP Address, your User Agent, store and retrieve cookies on your browser, embed additional third party tracking, and monitor your interaction with that embedded content, including correlating your interaction with the content with your account with that service, if you are logged in to that service. 54 | * A link to each service's privacy policy has been included below. Where a general privacy policy is not available, the applicable country is indicated. 55 | 56 | * Amazon https://www.amazon.com/gp/help/customer/display.html?nodeId=468496 57 | * Animoto https://animoto.com/legal/privacy_policy 58 | * Blip https://blip.fm/corp/privacy 59 | * CollegeHumor http://www.collegehumor.com/static/privacy/policy 60 | * DailyMotion https://www.dailymotion.com/legal/privacy 61 | * Facebook https://www.facebook.com/about/privacy 62 | * Flickr https://policies.yahoo.com/privacy/flickr/ 63 | * FunnyOrDie.com http://www.funnyordie.com/about/privacy 64 | * Hulu https://www.hulu.com/privacy 65 | * Imgur https://imgur.com/privacy 66 | * Instagram https://help.instagram.com/155833707900388 67 | * Issuu https://issuu.com/legal/privacy 68 | * Kickstarter https://www.kickstarter.com/privacy 69 | * Meetup.com https://www.meetup.com/privacy/ 70 | * Mixcloud https://www.mixcloud.com/terms/ 71 | * Photobucket http://photobucket.com/privacy 72 | * PollDaddy https://polldaddy.com/privacy/ 73 | * Reddit https://www.reddit.com/help/privacypolicy 74 | * ReverbNation https://www.reverbnation.com/privacy 75 | * Scribd (US) https://support.scribd.com/hc/en-us/articles/210129366-Privacy-policy 76 | * SlideShare (LinkedIn) https://www.linkedin.com/legal/privacy-policy 77 | * SmugMug https://www.smugmug.com/about/privacy/ 78 | * Someecards https://www.someecards.com/page/privacy 79 | * SoundCloud https://soundcloud.com/pages/privacy 80 | * Speaker Deck https://speakerdeck.com/privacy 81 | * Spotify (US) https://www.spotify.com/us/legal/privacy-policy/ 82 | * TED https://www.ted.com/about/our-organization/our-policies-terms/privacy-policy 83 | * Tumblr https://www.tumblr.com/policy/en/privacy 84 | * Twitter https://twitter.com/en/privacy 85 | * VideoPress https://automattic.com/privacy/ 86 | * Vimeo https://vimeo.com/privacy 87 | * Vine https://vine.co/privacy 88 | * WordPress Plugin Directory https://wordpress.org/about/privacy/ 89 | * WordPress.tv https://wordpress.org/about/privacy/ 90 | * YouTube (Google) https://policies.google.com/privacy 91 | 92 | ## Registered Users 93 | 94 | * If you create an account on this site, you will be prompted to select a Username and provide your Email Address. 95 | * When choosing a Username, we strongly advise you not use or include your real name. Usernames cannot be changed. 96 | * Your Username and Email Address are stored in the website's database. Your Email Address is used to send you an email with a link to set your password or to send you an email with a link to reset your password in the event you forget your password. 97 | * Once an account is created, you must contact an administrator to have it deleted. 98 | * Accounts have a numeric User ID assigned to them when they are created. The User ID cannot be changed. 99 | 100 | ### Profiles 101 | 102 | * An anonymized string created from your email address (also called a hash) is provided to the Gravatar service to see if a Profile picture of you is available for display. The Gravatar service privacy policy is available here: https://automattic.com/privacy/ 103 | * You may optionally complete your Profile by providing your First Name, Last Name, Website (URL) and/or Biographical info. These additional details are also saved in the website's database. You may edit these details, and your Email Address, in your Profile at any time. 104 | * You may also choose how your name is displayed (your Display Name) to visitors to the site (e.g. in comments you create) in your Profile. 105 | * Your Username, First Name, Last Name and Email Address are accessible by administrators on the site. 106 | * Your Profile Picture (Gravatar), Display Name, Website (URL) (if any) and Biographical Info (if any) may be visible to visitors to the website (e.g. if you leave a comment or contribute an article). 107 | * If you author an article on the website, your Username, User ID, Profile Picture (Gravatar), Display Name, Website (URL) (if any) and Biographical Info (if any) are provided to any visitor using the website's REST API interface. 108 | 109 | ## Media 110 | 111 | * If you upload media (e.g. images) to the website, you should avoid uploading images with EXIF GPS location data included. Visitors to the website can download and extract any location data included in images on the website. 112 | * Visitors using the website's REST API interface can correlate uploaded media to a particular user. This may allow such visitors to map a user to a particular time and location if EXIF GPS location data was included in the uploaded media. 113 | -------------------------------------------------------------------------------- /v1archive/Roadmap.md: -------------------------------------------------------------------------------- 1 | # Main goal 2 | 3 | We cannot make WordPress sites compliant, but we can provide site administrators and users with the tools they need to help them bring their sites into healthy compliance. 4 | 5 | This project works towards the 25 May 2018 deadline, and the constraints and expectations, of GDPR. It does, however, take a wider view of online privacy in general, and considers privacy and data protection issues outside GDPR's explicit scope. 6 | 7 | This project has four goals. 8 | 9 | ## Add tools to core to facilitate compliance, and privacy in general. 10 | 11 | This area of work deals with data collection, retention, and user accounts in WordPress core. 12 | 13 | All GDPR related tickets in core can be accessed [here](https://core.trac.wordpress.org/query?status=!closed&keywords=~gdpr). All trac tickets being reviewed for this project can be accessed [here](https://github.com/gdpr-compliance/info/blob/master/Trac-Tickets.md). 14 | 15 | ### User data 16 | 17 | This section deals with user rights to view their data, to download it, and to have their data deleted. 18 | 19 | A good amount of this functionality already exists. Registered users ("author" and above) have access to almost all of their personal data on the User Profile screen. They also have access to all posts and comments they have made on the site, and can edit or delete them. Site owners can expect to deal mostly with requests from "contributor" level users as well as people that have commented on the site. 20 | 21 | A couple of tasks can be performed in core without additional tools. For example, a registered user’s account can be deleted and all of their posts can either be deleted or reassigned to another (already created) user account. This is sufficient for anonymizing a user account if there are no plugins that store private user data outside user_meta. Also, admins can search for and delete a specific user’s comments. 22 | 23 | However, having specialized tools will enable plugins to hook into the performed actions and do their share. This is critical as many of the top 100 plugins seem to store at least some private user data. Tools will also support user data requests on larger, more complex sites where manual review of posts and comments would otherwise take a lot of time. 24 | 25 | There will be two main tools: 26 | 27 | * A tool to export all personal data stored on the site (by email address or user login), see [#43438](https://core.trac.wordpress.org/ticket/43438), [#43440](https://core.trac.wordpress.org/ticket/43440), [#43546](https://core.trac.wordpress.org/ticket/43546), [#43547](https://core.trac.wordpress.org/ticket/43547). 28 | * A tool to delete all personal data and anonymize published/public content (like posts, comments, etc.), see [#43637](https://core.trac.wordpress.org/ticket/43637). 29 | 30 | * For commenters. The stored private data is emails and IP addresses, the rest is public. 31 | + Dialog for requesting to see and download their private data. 32 | TBD: should that data also contain the public portion? 33 | + Dialog for requesting deletion/anonymization of the data. 34 | TBD: Deletion or anonymization? Or both and let the site owner decide? 35 | + Ask for consensus for storing commenter cookies. This can be a (checked) checkbox under the comments form, something like “Save my name, email and site URL in my browser for next time I post a comment. More information”. 36 | * For registered users. All of the data stored by default is already visible in the user profile (except IP addresses if they have commented on the site), and most can be edited or deleted from there. 37 | + Button for downloading their private data, including IP addresses if they have commented. Again, should that also contain the public data? 38 | + Button for requesting deletion/anonymization of their account. 39 | 40 | The requests to see, download and delete/anonymize private data have to be with a confirmation (double opt-in) to avoid misuse. One solution is to send a token by email when a user or a commenter has requested access to or deletion/anonymization of their private data (see [#43443](https://core.trac.wordpress.org/ticket/43443) - the first version is already committed). The requester will have to submit that token as a confirmation of their request before the site owner can perform the action. While this could be done automatically, deleting and anonymizing will be non-reversible, and could also be subject to abuse. In this case it’s better if the site owners perform the actions themselves, after additional confirmation if required. 41 | 42 | There are several plugins that are implementing similar tools. 43 | 44 | ### Data collection and retention in core by default 45 | 46 | * Shorter texts about what information is collected in core, why, and what options users have, with links to more information. Needs text. 47 | * Create these “more information” pages on WordPress.org and/or the privacy resource site (see below). Needs text. 48 | 49 | ## Add tools for creating a privacy policy 50 | 51 | This area of work addresses GDPR-ready privacy notices. 52 | 53 | Site administrators whose sites collect or process data on EU residents will be required to display a privacy notice which uses plain, simple language to clearly explain data flows, retention, and user options. 54 | 55 | The goal is to add the functionality to help users generate a privacy notice, using tools which automatically report data collection and retention from the site's installed plugins. 56 | 57 | ### Collecting information for the privacy notice 58 | 59 | There will be wp_get_privacy_policy_page() helper functions for use in themes, etc. 60 | 61 | Another idea is to have a “postbox” shown when editing the policy page. All plugins that collect personal data or set cookies can output some concise information about what they collect and store and why. This information should be phrased for inclusion in the site’s privacy policy. 62 | 63 | ### Publishing the privacy notice 64 | 65 | The idea is to create the functionality for a special page for the privacy policy, [#43435](https://core.trac.wordpress.org/ticket/43435) (initial version of this is already committed), and [#43491](https://core.trac.wordpress.org/ticket/43491). The site owners are able to select an existing page or create a new one. 66 | 67 | The core privacy notice tool will also contain boilerplate text that the site owners can use to create their policies. The text will be used as the default privacy policy and will be inserted in the privacy policy page when a new one is created. See [#43473](https://core.trac.wordpress.org/ticket/43491). 68 | 69 | Generating a privacy notice is not an automatic task: the tools/functionality would assemble the required information for manual approval and publishing by the site administrator. 70 | 71 | ## Create some guidelines for plugins on compliance 72 | 73 | This area of work is examining the current plugin developer guidelines as they pertain to privacy and data protection. 74 | 75 | It will look at legal requirements ahead of GDPR, for example developing to the Privacy by Design principles, and also at general plugin ecosystem issues, such as not being allowed to say that a legally-focused plugin will make a site "compliant". 76 | 77 | ## Add documentation/help for site owners on how to use these tools. 78 | 79 | This area of work will provide guidance for site administrators, plugin developers, and everyday users on how use the tools produced by this project. It will also provide general information on privacy and data protection issues, mindful of the need to discuss general best practice principles rather than one specific legal framework. 80 | 81 | This information will reside in a new, separate, side blog, currently under construction, and similar to the [Transparency Blog](https://transparency.automattic.com/). 82 | 83 | Please suggest areas you would like to see from the perspective of a developer, an admin, or an everyday user on the [information resources page](https://github.com/gdpr-compliance/info/blob/master/information-resources.md) and we will write that content for inclusion. 84 | 85 | Documentation could also be supplied under the Tools menu, inclusive of short explanations of what privacy tools are available and how to use them. It could also contain the actual tools, for example an input field for anonymizing commenters by email address. 86 | 87 | The documentation should also be available via the new Tools => Privacy screen. 88 | 89 | ## Current issues of concern: 90 | 91 | * There are few plugins, including Jetpack and WooCommerce, which have begun similar GDPR compliance work, dovetailing neatly with the Core project. Participants should keep an eye on these to avoid duplication of effort. 92 | * There are also various projects underway for non-Automattic plugins, including some independent GDPR compliance projects. It would be helpful if contributors to the latter plugins would participate/contribute in this GDPR project to avoid duplication of effort or miscommunication. 93 | * IP addresses may be considered personal data so they need to be deleted or anonymized. However do they need to be sent to the user when requesting to see or download their personal data? They are essentially third-party tokens used temporarily to access the Internet and the users have no control over them. Do other websites make them available? 94 | * Who are considered “controllers”? All admins on single install and all superadmins on multisite? Are admins on multisite controllers for their own site? 95 | -------------------------------------------------------------------------------- /v1archive/Synched-info.md: -------------------------------------------------------------------------------- 1 | # Information we Synch 2 | 3 | ## credits (not stored) 4 | - WordPress version 5 | - Locale 6 | 7 | ## core/version-check (all stored, except for those marked) 8 | - Site URL 9 | - Site IP address 10 | - WordPress version 11 | - PHP version 12 | - MySQL version 13 | - Locale 14 | - Number of sites (i.e., on a multisite install) (not stored) 15 | - Number of users (not stored) 16 | - Whether multisite is enabled or not 17 | - On Multisite installs, the URL of the parent blog (i.e., the parent blog of pento.blog is wordpress.com) 18 | - Initial DB version (corresponds with the version of WordPress that was initially installed for this site) 19 | - Report data on whether a site updated successfully or not 20 | 21 | ## plugins/update-check 22 | - Site URL (stored) 23 | - A list of all plugins installed (stored) 24 | - A list of all plugin translation files installed 25 | - A list of all locales enabled on the site 26 | 27 | ## themes/update-check 28 | - Site URL (stored) 29 | - A list of all themes installed (stored) 30 | - A list of all theme translation files installed 31 | - A list of all locales enabled on the site 32 | 33 | ## events: Information is hashed to create a cache key (i.e., so two people searching for “nyc” will get the same result). The hash can’t be reversed. 34 | - User’s partially anonymised IP address (e.g., 1.2.3.0, the last digit will always be 0) 35 | - Browser timezone 36 | - User entered location 37 | 38 | ## core/importers (not stored) 39 | - WordPress version 40 | - Locale 41 | 42 | ## translations (not stored) 43 | - WordPress version 44 | - Locale 45 | - Plugin/theme version 46 | - Plugin/theme slug 47 | 48 | ## themes/info (not stored) 49 | - User entered search data 50 | 51 | ## plugins/info (not stored) 52 | - List of installed plugins 53 | 54 | ## core/checksums (not stored) 55 | - WordPress version 56 | - Locale 57 | 58 | ## core/browse-happy (1 in 25 requests stored) 59 | - WordPress version 60 | - Site URL 61 | - Browser useragent 62 | -------------------------------------------------------------------------------- /v1archive/Trac-Tickets.md: -------------------------------------------------------------------------------- 1 | # Trac Tickets 2 | 3 | ## Core 4 | Please use this link to view active GDPR tickets in Core: 5 | https://core.trac.wordpress.org/query?status=accepted&status=assigned&status=new&status=reopened&status=reviewing&keywords=~gdpr&col=id&col=summary&col=keywords&col=owner&col=milestone&order=milestone 6 | 7 | ## Meta 8 | * [#1767](https://meta.trac.wordpress.org/ticket/1767) - Inform users upon registration, that the account can't be deleted or renamed 9 | 10 | ## Other general privacy issues, not explicitly GDPR 11 | 12 | ## Other (from major plugins) 13 | * [Buddypress #408](https://buddypress.trac.wordpress.org/ticket/408) - User Activity Import/Export Function 14 | * [Buddypress #7698](https://buddypress.trac.wordpress.org/ticket/7698) - GDPR 15 | * [Jetpack] (https://github.com/Automattic/jetpack/projects/17) - Jetpack GDPR repo 16 | * [WooCommerce #19284](https://github.com/woocommerce/woocommerce/issues/19284) - GDPR: Usage tracking opt-in 17 | * [WooCommerce #19278](https://github.com/woocommerce/woocommerce/issues/19278) - GDPR: Add support for personal data removal for a given email address 18 | * [WooCommerce #19277](https://github.com/woocommerce/woocommerce/issues/19277) - GDPR: Add support for personal data export for a given email address 19 | 20 | ## Other CMS GDPR projects (we learn from each other!) 21 | * [Drupal](https://www.drupal.org/project/issues/search?issue_tags=GDPR) - Drupal GDPR compliance project 22 | * [Joomla](https://volunteers.joomla.org/teams/compliance-team) - Joomla GDPR compliance project 23 | -------------------------------------------------------------------------------- /v1archive/Useful-links.md: -------------------------------------------------------------------------------- 1 | # Useful Links concerning GDPR 2 | 3 | ## Global infomation 4 | * Official Regulation in [PDF](http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN) and in [HTML](http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN) 5 | * WebDevLaw on [data protection (GDPR)](https://webdevlaw.uk/data-protection-gdpr/) 6 | * EU GDPR [Portal](https://www.eugdpr.org/) 7 | * [Automattic and GDPR](https://en.support.wordpress.com/automattic-gdpr/) 8 | * [GDPR factsheet](http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=614208) for Asia Pacific Privacy Authorities to understand the basic requirements included in the EU GDPR 9 | 10 | ## Plugins and Frameworks 11 | * Allendav GitHub - [Privacy Policy Shortcodes](https://github.com/allendav/wp-privacy-policy-shortcodes) 12 | * bjornjohansen Gdoc [GDPR Compliance in WordPress](https://docs.google.com/document/d/1xobfogTbr80kmYkvW1RcNsmkytTRkKQi20HxFZ8hr8I/edit#) 13 | * dejliglama framework [https://www.gdprwp.com/](https://www.gdprwp.com/) (Adopted into WP core) 14 | * Fernando Claussen plugin on [GitHub](https://github.com/trewknowledge/gdpr) and [repository](https://wordpress.org/plugins/gdpr/) 15 | * Van Ons plugin in the [repository](https://wordpress.org/plugins/wp-gdpr-compliance/) 16 | * AppSaloon plugin on [GitHub](https://github.com/WP-GDPR/wp-gdpr-core/) and [repository](https://wordpress.org/plugins/wp-gdpr-core/) 17 | * OpenGDPR - [https://www.opengdpr.org/](https://www.opengdpr.org/) 18 | 19 | ## Further reading 20 | * [https://www.codeinwp.com/blog/complete-wordpress-gdpr-guide/](https://www.codeinwp.com/blog/complete-wordpress-gdpr-guide/) 21 | * [https://ninjaforms.com/gdpr-compliance-wordpress-forms/](https://ninjaforms.com/gdpr-compliance-wordpress-forms/) 22 | * [https://www.fellowshipproductions.co.uk/make-your-website-gdpr-compliant/](https://www.fellowshipproductions.co.uk/make-your-website-gdpr-compliant/) 23 | * [https://digitalcontentnext.org/blog/2017/06/23/eus-general-data-protection-regulation-means-website-compliance/](https://digitalcontentnext.org/blog/2017/06/23/eus-general-data-protection-regulation-means-website-compliance/) 24 | * [http://www.wired.co.uk/article/what-is-gdpr-uk-eu-legislation-compliance-summary-fines-2018](http://www.wired.co.uk/article/what-is-gdpr-uk-eu-legislation-compliance-summary-fines-2018) 25 | * [https://ico.org.uk/media/for-organisations/documents/1624219/preparing-for-the-gdpr-12-steps.pdf](https://ico.org.uk/media/for-organisations/documents/1624219/preparing-for-the-gdpr-12-steps.pdf) 26 | * [Anonymisation: managing data protection risk and code of practice = 108 pages](https://ico.org.uk/media/for-organisations/documents/1061/anonymisation-code.pdf) 27 | * [https://www.smashingmagazine.com/2018/02/gdpr-for-web-developers/](https://www.smashingmagazine.com/2018/02/gdpr-for-web-developers/) 28 | * [GDPR and e-Privacy](http://privacylawblog.fieldfisher.com/2018/gdpr-plus-e-privacy/) as playmates 29 | * Privacy policy example [from UK](https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/where-should-you-deliver-privacy-information-to-individuals/) and also from [a site in Australia](https://www.sbs.com.au/privacy-policy) 30 | * [https://pagely.com/blog/gdpr-wordpress-2018-resources/](https://pagely.com/blog/gdpr-wordpress-2018-resources/) 31 | * Anonymizing Code: [https://ico.org.uk/media/for-organisations/documents/1061/anonymisation-code.pdf](https://ico.org.uk/media/for-organisations/documents/1061/anonymisation-code.pdf) 32 | * Guide to GDPR for webmasters, developers and business owners - https://silicondales.com/whitepapers/silicon-dales-guide-gdpr/ 33 | * [http://www.privacy-regulation.eu/](http://www.privacy-regulation.eu/) 34 | -------------------------------------------------------------------------------- /v1archive/information-resources.md: -------------------------------------------------------------------------------- 1 | # Information resources 2 | 3 | Targeted information for everyday site users, site administators, and developers to reference on their compliancec journeys. 4 | 5 | This information will be located on its own site (currently a construction zone.) (https://privacy.blog/) 6 | 7 | This site will also host resources and tools, or link to them elsewhere. Exact arrangement to be determined once they are ready. 8 | 9 | Let's aim for seven pages of content per area. 10 | 11 | ## Main areas 12 | 13 | ### Information for users 14 | + General overview of WP and privacy (can cannibalise from existing content) 15 | + Your individual rights 16 | + Your privacy options 17 | + Cookie choices (eg. link to http://www.youronlinechoices.com) 18 | + WP.com and privacy (just a link to https://automattic.com/privacy/) 19 | + What do do if you're concerned about a site 20 | + Something 21 | 22 | ### Information for site administrators 23 | + Privacy notices: what information is required for your site users (in progress, HB - also WC London talk 15/04) 24 | + Analytics and tracking (best practices) (HB will do at the end of April ahead of 26 May WC Belfast talk) 25 | + Site security (best practices) (please clarify what is needed here? - HB) 26 | + Your users rights, how to honor them (data deletion, access requests) (In progress - HB) 27 | + Cookies (HB will do later half of month - NB ePD not finalised) 28 | + Your web host and privacy (please clarify what is needed here? if not, could duplicate PIA info -HB) 29 | + Data processing agreements (PS) 30 | + Privacy Shield 31 | 32 | ### Information for developers 33 | + Developer guidelines (done, in draft: needs to be dovetailed with plugin developer guidelines work - HB) 34 | + Conducting a Privacy Impact Assessment (done, in draft - HB) 35 | + Privacy notices: what info is required about your plugin/theme (in progresss, as above - HB) 36 | + Consent and Legal Basis (HB to do) 37 | + Privacy by Design (HB to cannibalise WC Northeast presentation) 38 | + International data transfers (HB to do end of April) 39 | + Cookies and telemetry (HB to do - NB ePD not finalised) 40 | 41 | ## Tools 42 | 43 | 44 | ## Glossary 45 | 46 | * Personal data 47 | * Sensitive personal data 48 | * Data controller 49 | * Data processor 50 | * Personally Identifiable Information (American term, different from PD) 51 | * Subject access request 52 | * DPO 53 | * PBD 54 | * PIA/DPIA 55 | * Explicit consent 56 | * Implicit consent 57 | * Extraterritoriality 58 | * Data breach 59 | * Anonymisation 60 | * Pseudonymisation 61 | * Lead country of establishment 62 | * Legitimate interest 63 | -------------------------------------------------------------------------------- /v1archive/marketing.md: -------------------------------------------------------------------------------- 1 | # Marketing and promotion 2 | 3 | How we announce this work to the world, and what we're doing to bring awareness 4 | 5 | ## Internal blog posts 6 | 7 | - [Make.core post for w/c 9 April](https://wordpress.org/news/2018/04/gdpr-compliance-tools-in-wordpress/) - Andrew Ozz 8 | - Make.core post for w/c 23 April 9 | - Make.core post for w/c 7 May 10 | - Make.core post for w/c 21 May (compliance week) 11 | 12 | ## External blog posts 13 | 14 | - [WPMU DEV - Everything You Wanted to Ask a GDPR Expert but Were Afraid to Ask with Kåre ](https://premium.wpmudev.org/blog/everything-you-wanted-to-ask-a-gdpr-expert-but-were-afraid-to-ask/) 15 | - Post for WP Tavern - HB 16 | - [WP Tavern - #GDPR-Compliance team formation post](https://wptavern.com/new-team-forms-to-facilitate-gdpr-compliance-in-wordpress-core) 17 | - [WP Weekley ep. 298 with Heather Burns](https://wptavern.com/wpweekly-episode-298-gdpr-user-privacy-and-more-with-heather-burns) 18 | - [GDPR for WP - Project going into WP Core](https://www.gdprwp.com/gdpr-going-into-wordpress-core/) 19 | - [WP Tavern - GDPR for WP momentum post](https://wptavern.com/gdpr-for-wordpress-project-gains-momentum-proposal-receives-positive-response-from-developer-community) 20 | - [WP Tavern - GDPR for WP launch post](https://wptavern.com/gdpr-for-wordpress-project-seeks-to-provide-a-standard-for-plugin-compliance) 21 | 22 | ## Podcasts and videos 23 | 24 | - Leo on [WP Watercooler](https://www.wpwatercooler.com/video/ep269-gdpr-wordpress-what-you-need-to-know/) 25 | - Tavern podcast before compliance deadline- possibly 16 May 26 | - [WP Porto Meetup interview with @dejliglama](https://dejliglama.wordpress.com/2018/02/22/meetup-porto-interview-about-gdpr-for-wp/) 27 | - WP Campus podcast(https://wpcampus.org/podcast/) Recording 18 April, publishing date TBC 28 | - Post Status discussed the project but did not invite anyone on(https://poststatus.com/all-about-your-privacy-draft-podcast/) 29 | 30 | ## WordCamps 31 | 32 | ### Past 33 | - Antwerp: [Herman Maes](https://wordpress.tv/2018/04/03/herman-maes-10-wordpress-gdpr-fails/) 34 | - Vienna: [Clemens Graf](https://2018.vienna.wordcamp.org/session/dsgvo-kommt-bist-du-bereit-was-es-ist-warum-es-wichtig-ist-sich-damit-zu-beschaftigen-inkl-best-practices-fur-wordpress-co/) 35 | - London: [Heather Burns](https://2018.london.wordcamp.org/session/getting-your-privacy-notices-ready-for-gdpr/) 36 | 37 | ### Upcoming 38 | - VIP Workshop, Napa Valley: [Trew Knowledge](https://twitter.com/trewknowledge/status/983451687984750593) 39 | - Frontend United, Utrecht: [Heather Burns](https://www.frontendunited.org/sessions/privacy-data-protection-and-open-source-development) (discussing this project at a Drupal conference) 40 | - Belfast: Heather Burns [lightning talk](https://2018.belfast.wordcamp.org/sessions/#wcorg-session-1650) 41 | - Europe (Belgrade) [Heather Burns](https://2018.europe.wordcamp.org/session/developing-for-privacy-and-data-protection/) - Workshop - max 80 participants so please register 42 | -------------------------------------------------------------------------------- /v1archive/shorter-texts.md: -------------------------------------------------------------------------------- 1 | ##Shorter texts 2 | 3 | From the [4 April compliance chat recap](https://make.wordpress.org/core/2018/04/05/gdpr-compliance-chat-recap-april-4/): 4 | *"Some shorter/other texts will be needed to add to core, but can then have links to the final privacy blog: WP default policy, text for new user registration and on user profile screen, technical text about the new functions for developer.wordpress.org , chapter in the plugin handbook"* 5 | 6 | ### External links 7 | - WP default policy (presumably meaning [https://wordpress.org/about/privacy/](https://wordpress.org/about/privacy/) 8 | - Technical text about the new functions for developer.wordpress.org 9 | - Chapter in the plugin handbook (Collaborative effort in progress) 10 | 11 | ### Tooltips/UX 12 | - Text for new user registration and on-user profile screen 13 | -------------------------------------------------------------------------------- /v1archive/userdocs.md: -------------------------------------------------------------------------------- 1 | # User Privacy and your WordPress site 2 | 3 | Depending on your national or international privacy regulations (such as the European Union's General Data Protection Regulationm which may be applicable to you) you may be required to display a privacy policy disclosing your collection and sharing of personal data. Personal data includes things like your users' name, email, birthdate, phone number, IP address and other data that can be used to identify them. 4 | 5 | You may also be required to provide your users with the means to request a copy of the information you hold about them, or request its deletion. 6 | 7 | WordPress now includes several simple tools for site administrators to take these steps. These tools make it easier for you to inform your users through a transparent privacy notice about data that is collected on your site. It usually includes at least: 8 | - What data you collect about them, 9 | - Why and how you collect data, 10 | - And what you do with that data (including with whom who you might share that data). 11 | 12 | These new tools also make it easier for users to request a copy of their data or its removal. The use of the new data privacy tools (whether required by law or not) will make it easier for you to protect your users' privacy. 13 | 14 | Please note: Every website is different. No two privacy notices will be alike, just as no two site administrators will have identical compliance journeys. Additionally, new regulations, as well as adaptations of existing ones, may alter your compliance journeys. **We strongly encourage you to consider that safeguarding privacy is not a one-time responsibility.** Taking steps to secure and protect your users' data is a continuous process both online and offline. These tools can help you with parts of that process, but they are not a compliance process in and of itself. *We strongly encourage you to check the regulations and expectations applicable to you and adjust your usage of these tools as needed.* 15 | 16 | ## Privacy Settings 17 | 18 | This tool makes it easier to select and build a Privacy Policy page. It will create a dedicated page (or adapt an existing one) and provide prompts and headers to kickstart the process. 19 | 20 | Site administrators can create this page by going to *Settings > Privacy*, where the Privacy Policy page setting is managed. 21 | 22 | The prompts and headers provided in the tool by default are based on the expectations of Europe's GDPR as a leading privacy standard. While this gives you a start to build on, your privacy policy is not constrained by this starter text. *It is your responsibility* to write a comprehensive privacy policy, to ensure that it reflects all national and international legal requirements on privacy, and to keep your policy current and accurate. 23 | 24 | ### Privacy Policy Editing Helper 25 | 26 | The *Editing Helper* feature is part of the new *Privacy Settings* tool. Drawing information from both WordPress core and a site's themes and plugins, the Editing Helper pulls together a collected set of default texts which detail a site's data collection and sharing, generating a starter text which you can use to complete your privacy policy. 27 | 28 | While you do not necessarily need to use this tool to build a Privacy Policy, we believe it is helpful because it provides information on how your WordPress site likely collects and processes data in core, theme and plugin code. It is important to consider these back-end uses of data: While not all sites will use all functions (for example, an administrator may choose not to enable comments on posts) nearly every site uses features such as analytics cookies, social media sharing buttons, or contact form plugins. Please add as many additional disclosures as is necessary to be fully transparent about how your site uses personal data. 29 | 30 | *This tool ONLY collects policy help texts from WordPress and participating plugins.* Many sites will also embed third-party tools (such as email subscription services) which collect data in ways the the Editing Helper tool cannot detect, so the default template may not completely describe how your site might collect data about its user. Take the time to understand how your website actually collects your users' data, and be transparent about what actually happens with data on your website to your users. 31 | 32 | Further, theme and plugin developers are invited to learn how the Privacy Policy Editing Helper works, and to feed in the information about how your theme or plugin collects data into the privacy policy tool. 33 | 34 | ## Export Personal Data tool 35 | 36 | WordPress now includes a feature to to archive user data for export. This is different from the _Tools > Export_ tool which creates an archive file of posts, pages, or media; the new tool exports in captured elsewhere. You can use this tool by clicking on _Tools > Export Personal Data_ in your WordPress dashboard. 37 | 38 | This tool manages email export requests by your users. Following manual approval, it allows you to generate a (`.zip` format) file containing the personal data which exists about a user within your WordPress site. 39 | 40 | *We strongly encourage you use the email validation feature built into the export tools. This confirmation process will help safeguard against abuse, such as malicious users pretending to be someone they are not.* As with the Erasure tool, the Erase Personal Data tool uses email validation to send a user's request to an administrator. The administrator must manually approve the request to send the data in question to the user. 41 | 42 | *As this tool ONLY gathers data from WordPress and participating plugins, you may need to go beyond to comply with export requests.* While it may give you a good start in providing your users with the information they have requested, every site administrator should understand what data they collect and process outside their WordPress site as a full site request may have more responsibility than simply using this export alone. 43 | 44 | While this tool's scope covers much of the scope of WordPress user data, it likely does not include information that may be collected by your site using a third-party service, such as an analytics provider, newsletter subscription service, ad affiliate partner or embedded media. 45 | 46 | ## Erase Personal Data tool 47 | 48 | Similar to the Export Personal Data tool, WordPress now includes a tool to delete a user's personal data upon verified request. You will find this feature under _Tools > Erase Personal Data_ in your WordPress dashboard. 49 | 50 | *We strongly encourage you use the email validation feature built into the export tool. This confirmation process will help safeguard against abuse, such as malicious users pretending to be someone they are not.* As with the Export tool, the Erase Personal Data tool uses email validation to send a user's request to an administrator. The administrator must manually approve the request to remove the data in question. 51 | 52 | *Deleted data is permanently removed from the database.* Erasure requests cannot be reversed after they have been confirmed. Note that it does not remove the data from backups or archive files: When using the tool alongside automated backups or archives, we advise you to exercise caution when restoring user data from backups. When restoring an archived copy of your site, your requests for erasure should be respected. 53 | 54 | *As this tool ONLY gathers data from WordPress and participating plugins, you may need to go beyond to comply with erasure requests.* While it may give you a good start in complying with your users' request to remvoe the information they have requested, every site administrator should understand what data they collect and process outside their WordPress site as a full site erasure request may have more responsibility than simply using this tool alone. 55 | 56 | In particular (as with the Export tool) it likely does not include information that may be collected by your site using a third-party service, such as an analytics provider, newsletter subscription service, ad affiliate partner or embedded media. 57 | 58 | *When erasing user data, this tool does not automatically delete registered users and their profile data.* Administrators should perform that step themselves after successfully erasing personal data for a registered user. User deletion is available for each user in the _Users_ menu in the Dashboard. 59 | 60 | *It is also important to understand that personal data deletion requests are not absolute.* A site administrator is not obliged to delete data that they may be required to keep for other legal or statutory reasons. For example, you may be required to keep sales records for a certain number of years for tax purposes. You may also wish to keep a user's records for security purposes, for example, if there is an ongoing investigation into abuse. These situations should be handled internally. 61 | 62 | ## Consent of data collected 63 | Under some privacy laws, you may also be required to have your users' active, clear, and unambiguous consent before collecting their personal data. Further, you may also be required to have your users' active, clear, and unambiguous consent before certain kinds of processing of personal data, if that processing isn't otherwise necessary for your site. 64 | 65 | While WordPress.org does not yet have consent tools built, [there are various plugins available](https://wordpress.org/plugins/tags/gdpr/) to help in collecting consent to be compliant with the May 2018 GDPR compliance deadline. In addition, WordPress Core intends to add additional tools for WordPress theme and plugin developers for consent management in WordPress Sites. 66 | 67 | Some plugins, especially in the case of forms and email subscription services, suggest that you add a "required" consent field that says something like [_"I consent to my submitted data being collected and stored"_](https://docs.gravityforms.com/wordpress-gravity-forms-and-gdpr-compliance/ 68 | ) if this is a requirement for your website. 69 | 70 | *** 71 | _Props to @allendav, @webdevlaw for help here._ 72 | 73 | Various notes: 74 | 75 | 1) To-do: Would be nice if we could add a "how-to-use" section by May 25 launch, see Woo article here doing a good job of this: 76 | https://woocommerce.wordpress.com/2018/05/04/woocommerce-3-4-gdpr-features/ 77 | 78 | 2) Note: Leaving in "Explicit Consent" even though we don't have much to show for it since it's pragmatically a major concern for major plugins. We should replace with content about WP core when we can. 79 | 80 | 3) Would like feedback on whether to use link one or two: 81 | - wordpress.org/plugins/tags/gdpr 82 | - https://wordpress.org/plugins/gdpr/ 83 | Link two is built by a well-respected development shop and does Explicit Consent the way it should be, but link one is less endorsement-heavy. 84 | --------------------------------------------------------------------------------