boxuk/gdpr

GDPR plugin

3.13.13 2022-05-23 09:51 UTC

Requires (Dev)

• automattic/phpcs-neutron-standard: ^1.5
• automattic/vipwpcs: ^2.0
• dealerdirect/phpcodesniffer-composer-installer: ^0.7.0
• phpcompatibility/phpcompatibility-wp: ^2.0
• phpunit/phpunit: ^8.0
• squizlabs/php_codesniffer: ^3.3
• wp-coding-standards/wpcs: ^2.0

GPL-2.0-or-later

README

⚠️	This is a fork of the plugin referenced throughout this README and codebase. This is forked for the specific needs of Box UK, so although it may be of benefit to others it is not maintained as to be relied upon.

GDPR

This plugin is meant to assist a Controller, Data Processor, and Data Protection Officer (DPO) with efforts to meet the obligations and rights enacted under the GDPR.

Documentation

http://gdpr-wp.com/knowledge-base/

Installation

1. Upload the plugin to the /wp-content/plugins/ directory or install directly from the [http://wordpress.org/plugins/gdpr](WordPress Plugin Repository).
2. Activate the plugin through the 'Plugins' menu in WordPress
3. Fill out all sections of the settings page.

Shortcodes & helper functions

http://gdpr-wp.com/knowledge-base/functions-shortcodes/

Features

• Consent management
• Privacy Preference management for Cookies with front-end preference UI & banner notifications
• Privacy Policy page configurations with version control and re-consent management
• Rights to erasure & deletion of website data with a double opt-in confirmation email
• Re-assignment of user data on erasure requests & pseudonymization of user website data
• Data Processor settings and publishing of contact information
• Right to access data by admin dashboard with email look up and export
• Right to access data by Data Subject with front-end requests button & double opt-in confirmation email
• Right to portability & export of data by Admin or Data Subject in XML or JSON formats
• Encrypted audit logs for the lifetime of Data Subject compliance activity
• Data Subject Secret Token for two-factor decryption and recovery of data
• Data breach notification logs and batch email notifications to Data Subjects
• Telemetry Tracker for visualizing plugins and website data

Settings

General From the Settings options in the dashboard, you can select the Privacy Policy page for tracking and logging consent.

On login, the user must consent to the Privacy Policy outlined on the site. If the user does not consent, the user will not be registered or logged in.

If the site owner updates the Privacy Policy page content, the change will be logged and flagged to the admin that they must notify users on next login to seek re-consent. Additionally, the warning message can be dismissed in the event of a minor correction or mistake.

Additionally, under General Settings the Admin can set the outgoing email limitation which would set the batch notification email limit per hour in the event of a Breach Notification.

Cookie Preference Management Similar to consent management, users can opt in or out of cookies that are being used on the site. There are 3 formats of cookies that can be created which include:

• Always Active: Cookies that are always active or are required for the site to function.
• Toggled: Cookies that can be activated or blocked based on the user preference
• Opt-Out Link: Cookies that require configuration from a third-party source in order to opt-out

Depending on the user preference setting, you can use the is_allowed_cookie( $cookie ) function to save and set the cookies. The cookie with the user approved cookies can be found at another cookie named gdpr_approved_cookies. There's also a helper function called is_allowed_cookie( $cookie ) that you can use to prevent setting up a cookie.

Consent Management

Consents can be registered on the settings page. They can be optional or not. By default, this plugin comes with a Privacy Policy consent that users need to agree with on registration.

For optional consents, there's a wrapper function have_consent( $consent_id ) to help you display or hide something on the site depending if the user gave consent or not.

Consents are logged to the user record for auditing or for access purposes.

Requests Table & Rights of Data Subject

Right to Erasure Requests

1. The Data Subject is able to submit a request to be erased from the site using a shortcode.

2. When a request is made, the Data Subject will receive an email confirmation to confirm the deletion request.

   1. After email confirmation, the user request is added to the requests table for review by the Administrator. The Administrator can also add a user manually with an email look up and review.
   2. If the Data Subject has content published on the site for any post types or comments, they will be added to this table. If they do not have any content, they will receive a confirmation of erasure request and be provided a 6 digit Token for safekeeping after erasure in case of recover data needs.
   3. The requests table allows the Administrator to reassign any content to another user or delete it.
   4. In the event of comments, the Data Subject’s content would be made anonymous.

3. Admin can also manually add users to the erasure requests table with a manual email search

Right to Access Data Request & User Data Portability

1. The Data Subject can place a request to download their data with the shortcode.
2. After requesting their data, the user will receive a double opt-in confirmation email then the plugin will generate an XML or JSON file, which will be emailed to them for download with an expiration time of 48 hours.

Right to Rectify & Complaint Requests

1. The Data Subject can place a request to rectify data or file a complaint with the shortcode.
2. After making their request, the user will receive a double opt-in confirmation email and then add them to the table for admin to handle the request.

Tools

Access Data

The Access Data tool allows the Admin to look up a user email and view the data of a particular user. The Admin can download and export the data in a JSON or XML format and provide to the Data Subject if manually requested.

NOTE: This method should not be used without the Data Subject confirming their identity.

Audit Log

Everything the Data Subject does from registration, providing consent to the privacy policy, terms of service and other requests are logged and encrypted in a database. Data breach notifications are also logged to all Data Subjects upon confirmation by Controller.

1. Using the Data Subject's email, you can look up and retrieve the user information and display it.
2. If the Data Subject has been removed from the site, this encrypted log is deleted from the database and saved as an encrypted file inside the plugin folder.

If in the future, the Data Subject makes a complaint or there is a need to recover the data, the user can provide their email address and the 6 digit token they received from the deletion confirmation email to decrypt and retrieve the file.

Data Breach & Notifications

In case of a data breach, the Admin can generate a Data Breach Notification to users by logging the information and confirm the breach through a double opt-in confirmation email. The following information would be recorded in the audit log:

1. Nature of the personal data breach
2. Name and contact details of the data protection officer
3. Likely consequences of the personal data breach
4. Measures were taken or proposed to be taken

Once the confirmation of the breach has been confirmed via email, the website will begin a batch email notification process to all users every hour until all users receive the notification.

Telemetry Tracker

The Telemetry Tracker feature will display all data that is being sent outside of your server to another destination. It will indicate the plugin or theme responsible, file and line where the data is being sent.

WordPress Core and some plugins gather data from your install and send this data to an outside server.

WordPress Plugin Repository does not allow plugins to do that, but premium plugins are able to do this because they are not bound by the Plugin repository rules. If you did not explicitly opt-in for this feature you should make a complaint.

Important!

Activating this plugin does not guarantee that an organization is successfully meeting its responsibilities and obligations of GDPR. Individual organizations should assess their unique responsibilities and ensure extra measures are taken to meet any obligations required by law and based on a data protection impact assessment (DPIA).

Frequently Asked Questions

What is GDPR

This Regulation lays down rules relating to the protection of natural persons with regard to the processing of personal data and rules relating to the free movement of personal data.

This Regulation protects fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data.

The free movement of personal data within the Union shall be neither restricted nor prohibited for reasons connected with the protection of natural persons with regard to the processing of personal data.

How do Businesses benefit from GDPR?

• Build stronger customer relationships and trust
• Improve the brand image of the organization and its brand reputation
• Improve the governance and responsibility of data
• Enhance the security and commitment to the privacy of the brand
• Create value-added competitive advantages

Who does the GDPR affect?

The GDPR applies to all EU organisations – whether commercial business, charity or public authority – that collect, store or process EU residents’ personal data, even if they’re not EU citizens.

The GDPR applies to all organisations located within the EU, whether you are a commercial business, charity or public authority, institution and collect, store or process EU citizen data. It also applies to any organisation located outside of the EU if they also collect store or process EU citizen data.

What is considered personal data?

The GDPR defines personal data as any information or type of data that can directly or indirectly identify a natural person’s identity. This can include information such as Name, Address, Email, Photos, System Data, IP addresses, Location data, Phone numbers, and Cookies.

For other special categories of personal data, there are more strict regulations for categories such as Race, Religion, Political Views, Sexual Orientation, Health Information, Biometric and Genetic data.

What are the penalties for non-compliance?

Organizations can be fined up to 4% of annual global turnover for breaching GDPR or €20 Million. This is the maximum fine that can be imposed for the most serious infringements.

There is a tiered approach to the fines whereby a company can be fined 2% for not having their records in order (Article 28), not notifying the supervising authority and Data Subject about a security breach or for investigating and assessing the breach.

Am I compliant just by activating this plugin?

No, this plugin is meant to assist a Controller, Data Processor, and Data Protection Officer (DPO) with efforts to meet the obligations and rights enacted under the GDPR.

Activating this plugin does not guarantee that an organisation is successfully meeting its responsibilities and obligations of GDPR. Organisations should assess their unique responsibilities and ensure extra measures are taken to meet any obligations required by law and based on a data protection impact assessment (DPIA).

Changelog

2.1.0

• Wrapping checkboxes in labels so they stay in the same line.
• Adding initial WPML and Polylang translation config file.
• A few text changes.
• Change email sender. This hopefully fixes the SMTP issue.
• Added an ON/OFF indicator next to toggles.
• Added close buttons to bars so they don't stop users from accessing footer links.
• Removed checkmark icon from the bar buttons. This checkmark was confusing some users.
• Added an extra parameter to the [gdpr_preferences] shortcode. You can use tab="target" to open the privacy preference window in a specific tab. Check plugin settings for available targets.
• Updating request error messages to not disclose if the user is a member of the site or not based on his email. This change is to protect users privacy.
• Added soft-optin option for cookies. This will allow these cookies on first landing just like required but it will allow for users to opt-out.
• Added an option to use a reconsent-modal screen instead of the bar. This modal has been reworked since v1 to look nicer. ( Highly requested after v2 update )
• Minor bug fixes.

2.0.10

• Fix new re-consent bar not showing if users had no prior consent.
• Added a PHP version check on activation.

2.0.9

• Fix a syntax error introduced after cleaning code with PHPCS.
• Fix functions that were not checking if registered consents were empty before running.

2.0.8

• Adding a setting to hide plugin generated markup from bots such as Googlebot.
• Fix cookie category dismiss button not showing up after adding a new category. A save was required before the button would appear.
• Display cookie categories that do not have anything in the cookies used option.
• Fix warnings when no consent is registered.
• Small style and markup enhancement.
• A little cleanup to reduce WP server stress.

2.0.7

• Changing some texts to be consistent.
• Cleaned up code with VIP Code Standard.
• Improved security.
• Fix internet explorer bug.
• Fix JS function with wrong variable name when an AJAX error happened.
• Fix Warning on woocommerce consent checkboxes.
• Renaming buttons and translating placeholders.
• Added another parameter to the request forms function and shortcode to allow users to customize the button text.
• Fix a bug in the privacy preferences center when you moved to a different page without accepting cookies it would uncheck fields that should continue being checked.
• Fix settings tooltips z-index to sit on top of other elements.

2.0.6

• Fix XML export error.

2.0.5

• Fix cookie toggle indicator set to on even if the user had previously untoggled it.
• Other minor fixes to the audit log reconsent.

2.0.4

• Adding two missing translation strings
• Removing debug code that I forgot to remove from 2.0.3
• Adding to audit log when user reconsents.

2.0.3

• Fix third party cookies now showing up in the privacy preferences window or the settings page.

2.0.2

• Fix reconsent not logging correctly on reconsent
• Fix reconsent bar not showing up.

2.0.1

• Removing things that should have been deleted prior to updating to 2.0.0.
• Fix new reconsent bar missing closing div.

2.0.0

• Change all requests and privacy preferences window to AJAX to avoid the admin-post hook issue.
• We do not track privacy policy anymore. We can now track any kind of policy that users want. Those have been moved to each consent.
• Including more options. Including "enable/disable" the privacy bar.
• New filters and funtions were included.
• Making the settings a little more accessible.
• Removed the reconsent modal. It was too obtrusive. We switched to a more subtle notification bar.

1.4.7

• Fix for users who were complaining about their scroll bars missing if they did not select a privacy policy page.

1.4.6

• Change re-consent logic so it doesn't influence SEO with repeated content.

1.4.5

• Minor style adjustments
• Body scroll is disabled when modal is active
• Adjusting privacy bar to sit behind re-consent modal

1.4.4

• Fix all_cookies field being displayed as text field instead of hidden.

1.4.3

• Found one more instance of Telemetry Scanner, changed to Telemetry Tracker.
• Delete cookies when users change their preferences and disable some cookies.
• Changed cookies used field to textarea for easier reading when lots of cookies are set.
• Added a text to the settings page explaining that even if cookies are registered, if the user does not input some text for the privacy banner, it won't show up.
• Adding filters for the admin notification email. https://gdpr-wp.com/knowledge-base/actions-filters/
• Adding filters for the request forms button label. https://gdpr-wp.com/knowledge-base/actions-filters/

1.4.2

• Fix privacy bar reapearing. Cookie was not set to expire in a year.

1.4.1

• Allow links in the consent description in the wp profile page.
• Force tabs to be an array when empty to fix the notices and fatal error in the front end.
• Hide cookies sidebar in the privacy centre window if no cookies were registered.
• Adding a filter so the privacy bar button text can be changed.
• Changing Telemetry Scanner to Telemetry Tracker for consistency across the plugin.
• Translating missing strings.
• Adding options to add or remove consent checkboxes to woocommerce registration form and checkout registration form.

1.4.0

• Adding the option to disable the plugin CSS. Be careful when using this option. Make sure you know what you are doing.
• Adding the option to enable or disable the telemetry feature.
• Adding the option to add reCaptcha to the request forms.
• Adding comments to the personal data export.
• Moved privacy bar content field and privacy excerpt field to the general settings tab.
• Removed automatic privacy policy link from the privacy bar.
• We now accept links in the privacy bar content to get around the last change.
• Changed Telemetry cleanup schedule to hourly.
• Forcing the privacy bar to stay on the left to avoid CSS incompatibilities.
• Renaming the tab classes in the admin panel to again avoid incompatibilities.
• Fix privacy preference centre only showing up when cookies were registered.

1.3.5

• Fix undefined variable warning.
• Fix WooCommerce and possibly other plugins nonce manipulation for logged out users. For real this time.
• Fix XML export fatal error when meta key starts with a number.

1.3.4

• Prefixed all nonce actions.
• Fixed cookies being checked by default when they should have been unchecked.
• Possible fix for strange characters causing XML export to throw an error.
• Fix for WooCommerce nonce manipulation for logged out users that was preventing visitors from updating their privacy preferences.

1.3.3

• Fix translation error everybody has been complaining about.

1.3.2

• Fix issue with the is_allowed_cookie JS function.

1.3.1

• Fix consent syncing when difference comes from database and not the cookie.
• Might allow people to use external services like iubenda.

1.3.0

• Added BuddyPress registration form integration.
• Added WooCommerce registration and checkout registration form integration.
• Added admin notifications when a user makes a request that requires interaction.

1.2.2

• Adding a couple missing translation strings.
• Wrapping the telemetry post type page in an if so people can unregister it if they want to.

1.2.1

• After one user reported that their scroll bar disappeared I decided to remove the code that do that when the reconsent modal shows up. This has no impact on anything, but it might fix this user problem.

1.2.0

• Fix has_consent and is_allowed_cookie JavaScript functions not being available globally.
• Add a function to get the consent checkbox without echoing them.
• Change how the user deletion request works. We removed the email attachment to avoid being considered spam. The user can now download it immediatelly by clicking on their email link.
• Adding an option for user deletions always be added to the request review table. That will allow you to remove your users from third-party services before removing them from your site.

1.1.6

• Fix weird javascript issue that was preventing users from using the "Close my account" feature.

1.1.5

• The gdpr_request_form PHP function was returning instead of echoing. That is now fixed.
• Fix issue when syncing consent cookie and database values.
• Fix issue that prevented the privacy bar from disappearing after saving privacy preferences.

1.1.4

• Possible fix for cached sites.
• Added has_consent and is_allowed_cookie functions to javascript.
• Changed how the privacy bar and re-consent modal show up based on javascript.
• Better sync of consent and cookies with a cookie.

1.1.3

• Changed Complaint and Rectification form submit button wording.
• Added a loading indicator on the reconsent window. Slow servers will not give the impression that this featured is not working anymore.
• Fixed user notification not showing after confirming deletion email.
• Fixed consent "required" toggle not displaying the correct state.
• Added a second confirmation after disagreeing to reconsent.

1.1.2

• Fixed reconsent modal not closing after agreeing to the new policy.

1.1.1

• Forgot to unload jQuery-UI

1.1.0

• Merge the two preferences windows into one.
• [gdpr_preferences] shortcode doesn't need the 'type' attribute to work anymore.
• Removed jQuery UI from the front end and replaced with our own notification window to keep a consistent color scheme, avoid unnecessary requests and avoid style issues from theme to theme.
• Allow logged out users to keep track of consents too. ( Those are not logged to the audit log for obvious reasons. )
• Added a refresh after preferences change so users can display forms or count the user visit and so on depending on the new user consent.

1.0.6

• Allowing users to add target on their privacy policy links on the consent description.

1.0.5

• Allow users to use links on their consent descriptions so they can link to their privacy policy or other pages.

1.0.4

• Added a link to the privacy policy page on the cookie bar and on the cookie preferences window.
• Added a new option for a text just before the privacy policy link on the cookie bar.
• Checking if the user actually registered cookies before showing the cookie bar.

1.0.3

• Added a shortcode for re-opening the cookie or consent management windows.

1.0.2

• Added new filters for access data so extensions can add more information.
• Rebuilt the translation pot file and added translation comments.

1.0.1

• Fix issue on cookie preferences not saving and displaying php errors.

1.0.0

• Added cookie management screen
• Added consent management screen
• Added Telemetry tracker
• Complete code rewrite
• Added more types of request
• Added Help documentation
• Added new shortcodes
• Changed to Settings API

0.1.1

• Set the admin email as the default processor information on activation
• Settings updated notice is now dismissible

0.1.0

• Beta version released to the public

Upgrade Notice

1.0.0

This is a major rewrite of the plugin. Things will look different and work differently. We tried to keep most things the same so the impact would be minimal. This plugin is no longer in BETA. Update with care

0.1.0

This plugin is in beta. Use it at your own discretion.