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GDPR updates for Invision Community 4.3.3

Unless you've been living under a rock, or forgot to opt-in to the memo, GDPR is just around the corner.

Last week we wrote a blog answering your questions on becoming GDPR compliant with Invision Community.

We took away a few good points from that discussion and have the following updates coming up for Invision Community 4.3.3 due early next week.

Downloading Personal Data
Invision Community already has a method of downloading member data via the member export feature that produces a CSV.

However, we wanted Invision Community to be more helpful, so we've added a feature that downloads personal data (such as name, email address, known IP addresses, known devices, opt in details and customer data from Nexus if you're using that) in a handy XML format which is very portable and machine readable.

 

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You can access this feature via the ACP member view

The download itself is in a standard XML format.

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A sample export

Pruning IP Addresses
While there is much debate about whether IP addresses are personal information or not, a good number of our customers requested a way to remove IP addresses from older content.

There are legitimate reasons to store IP addresses for purchase transactions (so fraud can be detected), for security logs (to prevent hackers gaining access) and to prevent spammers registering. However, under the bullet point of not storing information for longer than is required, we have added this feature to remove IP addresses from posted content (reviews, comments, posts, personal messages, etc) after a threshold.

The default is 'Never', so don't worry. Post upgrade you won't see IP addresses removed unless you enter a value.

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This new setting is under Posting

Deleting Members
Invision Community has always had a way to delete a member and retain their content under a "Guest" name.
We've cleaned this up in 4.3.3. When you delete a member, but want to retain their content, you are offered an option to anonymise this. Choosing this option attributes all posted content to 'Guest' and removes any stored IP addresses.

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Deleting a member

Privacy Policy
We've added a neat little feature to automatically list third parties you use on your privacy policy. If you enable Google Analytics, or Facebook Pixel, etc, these are added for you.

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The new setting

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Finding Settings Easily
To make life a little easier, we've added "GDPR" as a live search keyword for the ACP. Simply tap that into the large search bar and Invision Community will list the relevant settings you may want to change.

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These changes show our ongoing commitment to helping you with your GDPR compliance. We'll be watching how GDPR in practise unfolds next month and will continue to adapt where required.

Invision Community 4.3.3 is due out early next week.

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1 hour ago, Upgradeovec said:

I just want to say - you can't manage personal data information, stored as a part of content.

Well that all depends if your software causes the personal information to be published or if its a third party. In your example a third party (re)posts personal information, not you. Its very common in other cases that if you do something to the "best of your abilities" it is considered to be enough. In such highly speculative instances you are obliged to remove such personal information as soon as you get notified not before.

When using a software like this and use the embedded function to quote someone I guess one could make a very compelling case against you. You as the publisher of the website know about the quote function, therefore it can be expected that if someone wants to have their personal information deleted you have to include known instances of such information.

Since it is entirely technically possible to provide a detailed history of every usage of personal information (aka store a log each time someone is quoted) you will have to delete the quoted parts or at least anonymize the username. The aspect of documenting the usage of personal information is a cornerstone of the GDPR.

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21 hours ago, DReffects2 said:

Oh and btw: of course video recordings in front of a bank are personal information. In fact they are so intensively personal that such recordings are not allowed in EU law.

Why would they be prohibited? There is absolutely a lawful basis under "legitimate interests" and possibly even "public task" too with the new GDPR - assuming this is carried out by the bank or a PSC on it's behalf.

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17 minutes ago, Aaron M said:

Why would they be prohibited? There is absolutely a lawful basis under "legitimate interests" and possibly even "public task" too with the new GDPR - assuming this is carried out by the bank or a PSC on it's behalf.

Because  is a public area. Inside the bank, where only visitors are recorded, it would be allowed. 

Edited by hjmaier
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5 hours ago, Aaron M said:

It is not illegal to record video facing out of premises.

I am no expert on UK law but I can tell you from experience that it is not allowed in Germany. It would be absolutely absurd if anyone could just install 8K PTZ Dome cams and zoom in on your girlfriends boobs, now would it?

While this has nothing to do with requirements for web tools I have to add: The new GDPR law trumps all local laws.

Not much of an impact in the UK i guess since they're leaving.... ?

giphy.gif

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53 minutes ago, DReffects2 said:

Not much of an impact in the UK i guess since they're leaving.... ?

 

As far as I know, even though they are leaving, they remain fully committed to the GDPR. 

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  • Management

You guys may wish to start a peer-based GDPR topic in the client lounge or similar to share your thoughts, tips and interpretations and carry on an ongoing dialogue amongst each other. You may pick up or be able to share some insightful information that will likely be lost in the shuffle here. 

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2 hours ago, steel51 said:

@MattCan we have 4.3.3. as soon as possbile? Monday is a bank holiday in many european countries. We could use this day to set up everything finally regarding GDPR. Thanks for all your efforts!

pretty please

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  • Management
7 hours ago, steel51 said:

@MattCan we have 4.3.3. as soon as possbile? Monday is a bank holiday in many european countries. We could use this day to set up everything finally regarding GDPR. Thanks for all your efforts!

Sorry guys, while 4.3.3 has the GDPR improvements, it also contains numerous bug fixes and so we need to carry it through our normal release schedule. We avoid late-week releases because we are not open for general support on the weekends. Tuesday is our target release date. 

Have a good weekend!

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On 5/18/2018 at 1:14 AM, DReffects2 said:

I am no expert on UK law but I can tell you from experience that it is not allowed in Germany. It would be absolutely absurd if anyone could just install 8K PTZ Dome cams and zoom in on your girlfriends boobs, now would it?

While this has nothing to do with requirements for web tools I have to add: The new GDPR law trumps all local laws.

Not much of an impact in the UK i guess since they're leaving.... ?

giphy.gif

Prominent signage must be placed saying CCTV is in effect and the ICO notified. You can read more here. Most EU countries take a more balanced approach, acknowledging the benefits of CCTV operation rather than Germany's overly strict regulation - same goes with IPS' implementation of GDPR compliant tools in 4.3.3; just because one country is overly strict doesn't mean the other 27 member states are. Also let's keep this apolitical, besides which the GDPR comes into effect prior to any departure from the EU anyway.

@Matt can previously unattributed posts be manually re-attributed, selectively, should a user return (under a new account) and want to pick up a thread/threads in the future?

Edited by Aaron M
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42 minutes ago, Aaron M said:

same goes with IPS' implementation of GDPR compliant tools in 4.3.3; just because one country is overly strict doesn't mean the other 27 member states are.

Business-wise not the best decision. While implementing all relevant data-privacy options would open up the software for each and every country the current approach does not. For countries that do not need feature X there's no downside, just don't use the feature. For countries that need a specific option it's more or less 'goodbye IPS'.

44 minutes ago, Aaron M said:

@Matt can previously unattributed posts be manually re-attributed, selectively, should a user return (under a new account) and want to pick up a thread/threads in the future?

I would strongly advise against it. Imagine someone else claims ownership of said postings. Especially if this happens with content that passes the threshold of originality this could create a big problem. If you keep a record of the previously assigned username in relation to the 'Guest_1234' substitute you are not deleting all personal information according to GDPR.

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19 hours ago, DReffects2 said:

Business-wise not the best decision. While implementing all relevant data-privacy options would open up the software for each and every country the current approach does not. For countries that do not need feature X there's no downside, just don't use the feature. For countries that need a specific option it's more or less 'goodbye IPS'.

I would strongly advise against it. Imagine someone else claims ownership of said postings. Especially if this happens with content that passes the threshold of originality this could create a big problem. If you keep a record of the previously assigned username in relation to the 'Guest_1234' substitute you are not deleting all personal information according to GDPR.

Even so, we cannot expect IPS to have to go through with a fine tooth comb for the specifics pertaining to every single country as there is certainly a downside in the rate at which updates would be delivered for everyone else. As they've already said, it will be better to react accordingly as to how the courts interpret the new legislature.

You can already so so by modifying the database directly anyway to change the post author. Additionally, this is a case for the provisions in the GDPR that permit the retention of data even after a deletion request. There's no point in a kneejerk reaction to "what ifs" until case law is built around the subject, and once this is so I have full confidence that IPS will adapt accordingly.

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23 hours ago, Aaron M said:

can previously unattributed posts be manually re-attributed, selectively, should a user return (under a new account) and want to pick up a thread/threads in the future?

I'm afraid not. When the attribution to a post is removed, it is removed. We no longer know who made which posts and have no way to find them in order to reassociate them (i.e. the member id, author name and IP address are all wiped out, so there's no way to even find all posts a previous user made at a technical level, which is sort of the point of anonymizing it).

If you leave user name attribution in place when deleting posts, then it would theoretically be possible at the database level at least.

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Hi,

Can anyone advise me or point me to any documentation regarding the following scenario:

Our company is registered in the UK, our userbase is worldwide and our server hosting two of our websites in question is located in the United States.

Anyone else have a similar configuration and do you have any advice on how to detail this regarding the requirement to disclose how information is transmitted internationally?

Thanks in advance

 

Regarding the new cookies addition - Will you be adding adsense as this also needs to be disclosed?

 

 

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6 hours ago, Aaron M said:

As they've already said, it will be better to react accordingly as to how the courts interpret the new legislature.

Said someone who clearly never had an Abmahnung ? Take Facebook for example: all bad press aside, FB reacted accordingly. Even a Lithuanian hosting company I do business with has responded with preemptive solutions. As well as every other company I do business with. All but one: IPS. The law is known since 2016 - we're in 2018 and theres not even a data processing agreement.

I do realize "lets see and react" is very american, but that does not help me or even pays my legal fees.

2 hours ago, Matt said:

Which is why we're watching GDPR closely but not knee-jerking a bunch of half baked features into life that may never be needed or used.

Using your resources right is very much appreciated. But don't you feel that you should assist your EU customers and provide solutions instead of a legal uncertainty? I do not expect that the check-box thingy for contact forms will emerge as the way to do things in the long run - but after this has been decided by the highest courts over here YEARS will pass. And hundreds of thousands of euros will be spent in order to reach this. I do not have 100k lying around nor the time. All while you are in risk of getting those cease and desist letters on a daily basis.

And since even government-run websites implement checkboxes these days - i'd like to be better safe than sorry.

?

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3 hours ago, Unlucky said:

Anyone else have a similar configuration and do you have any advice on how to detail this regarding the requirement to disclose how information is transmitted internationally?

For the data that leaves the EU please ensure that the hosting company in the US complies with the Privacy Shield Agreement. Please note that the previous "Safe Harbor" Agreement is not deemed enough according to the EU high courts.

There are several due diligence things for your to do:

  • Check and if your hoster in the US has a VALID certificate: www.privacyshield.gov/list
  • These certificates are to be checked and renewed every 12 months
  • If your hoster is not on the list you theoretically can bind him contractually but I guess that's not gonna happen.
  • Your hoster needs to provide a data processing agreement that is GDPR compliant

Personally, I would move the data to servers in the EU. Why host in the US in the first place?

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  • Management

@DReffects2 - I appreciate you've done extensive research as applicable to your situation jurisdiction. We have expended an enormous amount of time and resources aiding our EU clients with GDPR compliance to the best of our abilities and it's our understanding, we've actually done more than most similar platforms. A temporary line has to be drawn somewhere or we're going to end up with, as Matt said, a barrage of half-baked features and checkboxes everywhere. We have consulted with the ICO, our largest EU clients and perused legal resources and are confident that our implementation as of 4.3.3 will help satisfy your compulsory requirements under the GDPR. I know you don't like the "let's wait and see" approach on your remaining potential concerns, but that is in fact a key purpose of the judicial system -- interpreting and providing subsequent guidance on existing regulation.

We are committed to adapting and accommodating as needed, I assure you. We aren't, however, able to go crazy and toss things in based on armchair interpretations. From a layman perspective, a simple checkbox here and there seems easy. From a development perspective - you need to do something with that checkbox. As the contact form, when configured such, is merely an email form, there's nothing to do in the same way there's nothing to do when you actively send someone a traditional email -- you're sending the email because you want to initiate contact. If you wanted a "simple" checkbox on the contact form that's simply sending an email, you then need to provide a mechanism for obtaining consent, store the email address, store the consent, provide a mechanism to withdraw the consent to store the email, etc. None of that is necessary based on reasonable interpretations of the GDPR, so as developers with finite resources, we need to weigh out these requests that amount to a fair amount of development time with limited basis and simply say, if you're super concerned about untested, unchallenged, extreme interpretations for things like this, it's likely best, for your own peace of mind, to simply not use the feature.

I say with confidence that although ultimate compliance with any local, national or international law or regulation is the responsibility of the community owner; 4.3.3 is GDPR friendly. If you feel you need to be more restrictive based on additional member state requirements, interpretations or even personal peace of mind - you can of course disable embeds, disable the contact form, disable spam mitigation, disallow tech support and/or peruse third party solutions. It's my opinion, however, the EU authorities are not intending to cripple the Internet or make it cumbersome, inconvenient and unenjoyable to use; only to hold providers, controllers and processors to task for safeguarding data... and in that regard, it's only a good thing. 

There's a lot of information, opinions and suggestions floating through the comments here and it's difficult to keep track of. We welcome you to engage us via a support ticket for software and corporate specific information and, of course, you may use the client forums to discuss various scenarios, share opinions, tips, etc. 

We appreciate the feedback and participation. Let us know if we can be of further help.

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