Privacy experience in Plone and other open source CMS

Jörg Zell
Interaktiv GmbH
www.interaktiv.de
We are the good guys – aren`t
we?
Privacy Experience in Plone and
other Open Source CMS

Why does privacy
matter?
© Interaktiv GmbH 2 |

PRIVACY IS ONE PART OF USER EXPERIENCE
User
Experience
User
Design
Usability
Privacy
Many more..Security
Accessability
Performance

Source: https://www.statista.com/statistics/290525/cyber-crime-biggest-online-data-breaches-
worldwide/

Examples of recent privacy issues
 Facebook Security Breach in September 2018
50 Millon accounts compromised
 Facebook-Cambridge Analytica scandal
$134b loss in market value
 Yahoo: 250.000 pound fine in June 2018 over
breach
„ Yahoo failed to take appropriate technical
and organizational measures“
 Credit-monitoring company Equifax 2017 data
More than half of Americans affected
WHY PRIVACY MATTERS
Equifax data breach in numbers

Privacy experience is a global trend

GDP
R
Source: https://www.dlapiperdataprotection.com/index.html
APP
I
DPA
PIPEDA
Privacy Shield
State legislation
mix of Federal and
State legislation

DIFFERENT APPROACHES TO PRIVACY
Opt-in Opt-out
Personal Data
Ownership
Data belongs to the
service provider
Hard law Soft law
Centralized
Privacy as as
part of other
law subjects
Privacy as a
matter of
law
Decentralized
Trust in
government Trust in
business

29.01.2018 © Interaktiv GmbH 13 |
Source: https://www.nytimes.com/2018/09/28/technology/facebook-
hack-data-breach.html
Source: http://time.com/5421850/facebook-google-internet-bill-of-rights/

Internet Bill of Rights
transparency, privacy, control, notification,
N
net neutrality, competition, accountability

What follows from those different approaches for
a global open source community?

Source:
https://trends.builtwith.com/
cms/open-source

How can we ensure that we are the good guys?
 Awareness
 Privacy as an opportunity
 Privacy as a differentiator
Universal privacy standards?
COMMUNITY RESPONSIBILITY

Privacy experience in open source CMS
communities

Data minimisation
Data integrity
Purpose minimisation
Lifecycle limitation
Human and technical security measures
Transparency and notice
User participation and rights
Accountability, enforcement, and redress
Choice, control, and consent
Special categories of data
Legal compliance
“A collaborative best-practice approach to privacy in open
source development outside specific regulations and laws. “
PRIVACY IN OTHER OPEN SOURCE COMMUNITIES
Source: https://github.com/webdevlaw/open-source-privacy-standards

1. Data minimisation
Restrict the collection and processing of data to the minimum amount necessary; restrict access to data to the minimum amount of people and systems necessary; do not duplicate or aggregate data by default.
2. Data integrity
Ensure that the data collected and processed is correct, relevant, and up-to-date, especially if inaccurate or poor data could adversely impact the user;
3. Purpose minimisation
Only collect and process personal data for the purpose it was intended for, and for which the user was clearly informed of in advance;
4. Lifecycle limitation
Do not use personal data for other purposes, either active or potential. Delete data which is no longer needed, both in active use and in archives, by both the recipient and any third parties. Delete unnecessary data on a regular basis. Do
not share data with others at any point its lifecycle without a justified reason and user consent.
5. Human and technical security measures
Take adequate information security measures to protect the data from misuse and its subjects from harm. These measures must be technical (systems, software, code) as well as human (staff training, guidelines, and supervision).
6. Transparency and notice
Inform users how their data is being collected, processed, and shared; inform users what rights and choices they have over those uses; make your privacy standards public and accountable.
7. User participation and rights
Give users rights to access their data, download data, correct errors, and to control your collection and processing of it; give users the ability to ask you to stop using their data and to delete their accounts.
8. Accountability, enforcement, and redress
Document your collection and processing of data; protect it in transit to and from third parties; prevent misuse and breaches as much as is possible. Fix problems when things go wrong, provide redress when data is misused, leaked, or
breached; be morally and legally accountable to regulatory systems.
9. Choice, control, and consent
Give users and visitors choices and options over your uses of their data; require clear, specific, and informed opt-in; inform users of changes in uses and processing; give people access to their options and rights at any time through settings
and control panels.
10. Special categories of data
Take extra technical and human security measures to safeguard sensitive data which could result in the people it is about being hurt. This may include information about a person's race, religion, health, sexuality, location,
genetic/biometric information, etc.
11. Legal compliance
Ensure that the work meets the privacy regulations of the location where it will be used to collect and process people’s data. Work cooperatively and productively with regulations, laws, and supervisory bodies.
UNIVERSAL PRIVACY PRINCIPALS

Privacy Impact Assessments (PIAs) are the first step in a Privacy by Design (PbD) approach to development.
A PIA is the process by which questions about data collection, processing, sharing, storage, and access are
asked before the work has begun.
Data collection and retention
What personal data is processed?
How is that data collected and retained?
Is the data stored locally, on our servers, or both?
For how long is data stored, and when is the data deleted?
Is the data collection and processing specified, explicit, and legitimate?
What is the process for granting consent for the data processing, and is consent explicit and verifiable?
What is the basis of the consent for the data processing?
If not based on consent, what is the legal basis for the data processing?
Is the data minimized to what is explicitly required?
Is the data accurate and kept up to date?
How are users informed about the data processing?
What controls do users have over the data collection and retention?
Technical and security measures
Is the data encrypted?
Is the data anonymized or pseudonymized?
Is the data backed up?
What are the technical and security measures at the host location?
Personnel
Who has access to the data?
What data protection training have those individuals received?
What security measures do those individuals work with?
What data breach notification and alert procedures are in place?
What procedures are in place for government requests?
Subject access rights
How does the data subject exercise their access rights?
How does the data subject exercise their right to data portability?
How does the data subject exercise their rights to erasure and the right to be forgotten?
How does the data subject exercise their right to restrict and object?
Legal
Are the obligations of all data processors, including subcontractors, covered by a contract?
If the data is transferred outside the European Union, what are the protective measures and safeguards?
Risks
What are the risks to the data subjects if the data is misused, mis-accessed, or breached?
What are the risks to the data subjects if the data is modified?
What are the risks to the data subjects if the data is lost?
What are the main sources of risk?
What steps have been taken to mitigate those risks?
PRIVACY IMPACT ASSESSMENTS

 GDPR Compliance Team
 Privacy roadmap: https://make.wordpress.org/core/roadmap/privacy
 Wordpress core is GDPR compliant: privacy notice, data export, data
 Privacy by Design approach
 Documentation and resources for developers: guidelines on how to
 Resources for site administrators why privacy matters and what to do
 Resources for plugin developers:
https://developer.wordpress.org/plugins/privacy/

 Drupal GDPR Compliance Team
 Documentation about (more than 20) Drupal software tools for GDPR
compliance
 6 talks about privacy at Drupal Europe conference this year

 Privacy tool suite: https://docs.joomla.org/J3.x:Privacy
 Privacy Dashboard, Health Check, Plugins for Privacy Consent, Terms and Conditions
 Documentation for developers
 Github: „Collaboration space to work on a privacy framework for Joomla” - 580
contributors - https://github.com/joomla-projects/privacy-framework
 Marketing!

Privacy experience in Plone

Thursday, 15:20
Matthew Wilkes
Privacy best practice and Plon

Done
 https://github.com/collective/collective.privacy
 … probably many individual code snippets for cookie consent notices…
PRIVACY IN PLONE DEVELOPMENT
Some suggestions for discussion
 Assessment: What is the status of privacy in Plone core?
 Guidance: Should development documentation include privacy?
 Adhere to privacy best practices and follow Privacy by Design principals
 Features: Develop more privacy features: data export, data erasure, privacy notice, …
 Products: What about plugins/products and themes?
 Roadmap?

Proactive not reactive; preventive not remedial
Privacy as the default
Privacy embedded into design
Full functionality —postive-sum, not zero-sum
End-to-end security—lifecycle protection
Visibility and transparency
Respect for user privacy
PRINCIPLES OF PRIVACY BY DESIGN
Privacy by
Design
Read on: https://medium.com/searchencrypt/7-principles-of-privacy-by-design-
8a0f16d1f9ce

PRIVACY IN PLONE COMMUNICATION AND MARKETING
Done
 Talk about Privacy on plone.com, plone.org, Community.plone.org
 Documentation
 Privacy statement like Accessiblity statement in vanilla Plone
 Conference talks
 Promote privacy as a positive cultural value instead of a legal constraint
 Use transparency and privacy as a differentiator – we are the good guys!

PRIVACY IN PLONE COMMUNITY WORK
 People!
 Interested in an Open Space?
 Sprint work?
 Can we join forces with other communities?
Done
?

We are the good guys – let’s show it to the world.
PRIVACY PRIORITIES

You‘ll find this presentation on
Slideshare.
THANK YOU
zell@interaktiv.de
#InteraktivKoeln
https://www.linkedin.com/in/joergzell/
https://www.linkedin.com/company/interaktiv-gmbh
https://www.xing.com/profile/Joerg_Zell/
https://www.xing.com/companies/interaktivgmbh
By e-mail:
On Twitter:
At LinkedIn:
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Contact
me

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