collective.privacy 1.1.0a1

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:

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:

Storages

The storage determines how the user’s preferences are persisted. There are three storages available:

Cookies

This attribute lists the cookies that should be deleted if the user objects to the use of the corresponding data processing. It is optional and may contain wildcard (*).

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.

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 [llasudry]

• Allow to delete specified cookies if user objects to their use [llasudry]

• Add Dutch translation [llasudry]

• Add link to manage privacy settings [llasudry]

• Translate all messages / data processing reasons [llasudry]

• Fix consent submission [mpeeters]

• Fix validator for sendto_email [mpeeters]

• Add French translations [llasudry]

• 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]