An add-on for Plone that provides functionality for better complying with the EU's General Data Protection Regulations and ePrivacy Regulations
Project description
collective.privacy
This Plone add-on adds concepts from the EU’s General Data Protection Regulations to Plone configuration, which makes it easier to create Plone sites that respect the privacy rights of indivuals.
Features
ZCML based declaration of uses of data
User-facing privacy management form
Integration with core Plone features
Core Plone
The following core Plone overrides are included:
The sendto_form now validates a to email address against people who have opted-out. The legal basis chosen by default here is legitimate_interest.
The analytics viewlet also relies on legitimate interest, on the basis that it assumes the tracking is unobtrusive and that this will be allowed by the upcoming changes to the ePrivacy regulations. If the tracking is obtrusive or the site owner doesn’t want to make this assumption it should be overridden to use consent.
Examples
Users can define a new data processing reason as configuration. For example, an add-on that provides for embedding media might cause users to be tracked. The ZCML would be modified to include:
<configure xmlns="http://namespaces.zope.org/zope" xmlns:gdpr="http://namespaces.plone.org/gdpr" xmlns:i18n="http://xml.zope.org/namespaces/i18n" i18n_domain="collective.privacy"> <gdpr:data_use_category name="show_example_media_embed" title="Embedded media from example.com" description="We use example.com to embed media into the site. example.com monitors the usage patterns of users to provide enhanced analytics to site owners." legal_basis="consent" identifier="collective.privacy.identifiers.CookieIdentifier" storage="collective.privacy.storage.CookieStorage" cookies="media_cookie_*,other_cookie" /> </configure>
This would add a new item to the privacy controls that relies on consent to proccess data. This means that by default the permission is denied until an end user gives permission.
Note that the i18n domain of your configuration must be collective.privacy if you want to translate titles and descriptions of your new data processing reasons.
You can then guard your uses of the data, for example:
<div tal:condition="python: context.portal_privacy.processingIsAllowed('show_example_media_embed')"> ... </div>
Legal basis
GDPR provides for six legal bases for processing, all of which are supported by collective.privacy.
They are:
consent
Processing is disallowed by default, users can opt-in. There are rules as to what makes consent valid, which must be followed.
contract
Processing is allowed and users cannot object.
legal_obligation
Processing is allowed and users cannot object.
vital_interest
Processing is allowed and users cannot object.
public_task
Processing is allowed by default, but users may object. This is only suitable for certain specific types of processing.
legitimate_interest
Processing is allowed by default, but users may object.
Identifiers
It is necessary to tell one user from another when managing their preferences. In some cases different identifiers are more useful than others. For example, when sending email we want to key users on the email address, but using cookies should be managed by the browser, regardless of the user’s logged in state.
The way of choosing which is used is called a identifier. The following are available:
collective.privacy.identifiers.EmailIdentifier
This identifier should be used when the user needs to be identified by email address. It can optionally use the email address of a logged in user to identify the current request, but in general it cannot identify the current user.
The identifier is a UUID derived from the email address using a one-way function, not the email itself.
collective.privacy.identifiers.IPIdentifier
This identifier should be used to identify a connection. It can be used to identify the current user or other arbitrary users. It is less reliable than the CookieIdentifier as users IP addresses can change.
The identifier is a UUID derived from the IP address using a one-way function, not the IP itself.
collective.privacy.identifiers.UserIdentifier
This identifier can only be used to identify logged-in users. It can identify any users who are registered on the site, but not anonymous visitors. As such, it’s appropriate for data processing that only occurs for registered users.
The identifier is a UUID derived from the user name using a one-way function, not the username itself.
Storages
The storage determines how the user’s preferences are persisted. There are three storages available:
collective.privacy.storage.DatabaseStorage
This storage uses BTrees inside the portal_privacy tool to store the time the user consented or objected. It is currently the only storage that allows for the preferences of users to be queried outside of a request they have initiated.
collective.privacy.storage.NoChoiceStorage
This is a stub storage to be used with legal bases such as vital_interest where the user has no option to object to processing.
Translations
This product has been translated into
French
Dutch
Installation
Install collective.privacy by adding it to your buildout:
[buildout] ... eggs = collective.privacy
and then running bin/buildout
Varnish
If you use this product combined with Varnish ensure that your Varnish config does not remove cookies for requests where caching should be ignored
Example of config:
if (req.http.Cache-Control ~ "(private|no-cache|no-store)" || req.http.Pragma == "no-cache") { return (pass); }
Thanks
Thanks to Jazkarta ( http://jazkarta.com/ ) and YES! Magazine ( http://www.yesmagazine.org/ ) for each sponsoring some of the development costs of this add-on.
The irony that these are both US companies is not lost on us.
Contribute
Issue Tracker: https://github.com/collective/collective.privacy/issues
Source Code: https://github.com/collective/collective.privacy
Support
If you are having issues, please let us know.
License
The project is licensed under the GPLv2.
N.B., the GPL states:
THE COPYRIGHT HOLDERS AND/OR OTHER PARTIES PROVIDE THE PROGRAM “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. THE ENTIRE RISK AS TO THE QUALITY AND PERFORMANCE OF THE PROGRAM IS WITH YOU. SHOULD THE PROGRAM PROVE DEFECTIVE, YOU ASSUME THE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION.
This add-on has not received any contributors from lawyers and should not be interpreted as legal advice.
Contributors
Matthew Wilkes, matt@matthewwilkes.name
Martin Peeters
Laurent Lasudry
Changelog
1.1.0b2 (2022-01-07)
Fix Fixed ModuleNotFoundError: No module named ‘App.class_init’ on Zope 5. [laulaz]
Defer the execution of consent.js (#18). [comwes]
1.1.0b1 (2021-08-19)
Fix translation domain & add translations for custom text in send_to_form email [laulaz]
Fix traceback on send_to_form when sending an email : getConsentLink method must be accessible from template [laulaz]
Fix consent banner miss (when there are multiple cookies to accept) by ensuring JS event is only registered once on consent banner button. [laulaz]
Handle multilingual & subsites configurations by rendering consent form on navigation root (#15) [laulaz]
Fix JSON call for banner consent to get correct language in some multilingual configurations, if the current language must be taken from context (#14) [laulaz]
Ensure that consent banner shows on top (z-index) of everything else (eg: Google Maps) [laulaz]
1.1.0a1 (2020-05-12)
Add Python 3 and Plone 5.2 compatbility [mpeeters]
1.0b1 (2020-04-30)
Avoid caching for consent banner [mpeeters]
Don’t show consent banner on consent form [laulaz]
Allow to delete specified cookies if user objects to their use [laulaz]
Add Dutch translation [laulaz]
Add link to manage privacy settings [laulaz]
Translate all messages / data processing reasons [laulaz]
Fix consent submission [mpeeters]
Fix validator for sendto_email [mpeeters]
Add French translations [laulaz]
Add code to give better warnings around cookie use [MatthewWilkes]
Provide uninstall steps in profile (#1) [Mikel Larreategi]
Possible fix for diazo compatibility [MatthewWilkes]
Unintrusive analytics are legitimate [MatthewWilkes]
Remove unneeded skins call [MatthewWilkes]
Add missing files [MatthewWilkes]
Remove unneeded deps [MatthewWilkes]
1.0a1 (2018-08-25)
Initial release. [MatthewWilkes]
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