smd_access_keys: secure, limited access to content

jakob · 2018-05-18 20:34:51

Sorry, our posts are crossing and I can’t write fast enough ;-)

I guess it doesn’t matter how you record the consent. A possible pseudo-code method could be:

A user signs up. When the form is submitted, you log the email (plus name etc.) temporarily and generate an smd_access_key for it, then send that out as a confirmation link to the future recipient. The confirmation link could take the form of a query string appended to a page URL on your website.
The user receives the email and clicks on the confirmation link. On your page, you used smd_access_key to check against the GET url variable and if it matches, you transfer the email-address (plus name etc.) to your newsletter email list along with the timestamp of the confirmation, and thank the user.
Periodically you clear the queue to get rid of unconfirmed email details.

You could additionally log the IP-address if you think that is necessary as proof, but you don’t have to.

EDIT: it needn’t necessarily be two lists. You could simply have a consent timestamp column in your list and you could clear out all those without a timestamp from time to time.

saccade · 2018-05-18 20:46:08

Thank you very much, your informations are very helpful.

We keep our e-Mail-lists and -data separated from the website in our intern computers.
But to keep track I could think of generating an access_key automatically when the first opt-in happens. And user-data will be emailed or stored with an identifier to us. While an access_key and identifier is mailed to the user for second opt-in.
Then, when the second opt-in happens, only the identifier needs to be stored, together with a timestamp.

Only the IP-data bothers me:
In informations of the last year it has been mentioned as necessary for exact documentation of a real opt-in.
But is it really?
Or even: Is it allowed to be saved now under GDPR?

jakob · 2018-05-19 08:12:34

It looks like you’re right. You need the email address, the IP, the date and timestamp and the message (or form) they consented to. Googling around, it seems some store the sign-up time and IP and the confirm time and IP.

Is it allowed to be saved now under GDPR?

As far as I am aware, you can collect IP-addresses under GDPR if:

you inform your users, obtain their consent / offer them the ability to refuse consent.
you can demonstrate a legitimate interest, e.g. legislative necessity, for doing so without their consent.

We keep our e-Mail-lists and -data separated from the website in our intern computers

I guess it’s possible to have an emailing system that’s not directly coupled to the consent mechanism if your transfer mechanism is handled internally and efficiently according to GDPR practices. You need to provide people with an opt-out mechanism, so depending on how often you get new subscribers, or people unsubscribe, you might have a fair amount of manual work to do.

Bloke · 2018-05-20 16:34:05

I was thinking of removing the IP-collection part of this plugin (it’s optional via preferences, but is currently on by default: I could keep it and just make sure it’s turned off by default). This collects the IP address and when someone uses a key. It does nothing with the info, except store it and show you the IPs alongside the key.

I figured since storing it would probably land me in hot water, I was going to remove the feature entirely. Is that too hasty? Are there legit circumstances where it’s beneficial to keep the IP of an access attempt?

giampablo · 2018-05-21 15:23:25

Hello Stef,

now that texpattern 4.7.0 has been officially released can you please pack a new release of smd_access_keys with latest fixes?
I tried to compile the GitHub repo… without success :(

saccade · 2018-05-21 19:53:54

(i‘m on a vacancy with poor web connections so please forgive any mistakes)

As far as I know some advices recommend to save exactly when and from where (ip) a double-opt-in-confirmation has been confirmed. Maybe that‘s beyond the plain text of law, but to be able to really prove confirmation, this makes sense.
But in my view it also requires a special additional data protection info in the confirmation dialogue, since here you indeed save an ip and connect an ip to a person and personal data,
which I in turn regard as a dangerous culmination of data.

But also: I didn‘t find any info which says that an email or mailcontact is enough to prove the consent.
This would be my favourite: after first opt-in generate a key to confirm, when this key has been used a second mail generated by the key will prove consent.

isn‘t there anybody who has a proven workflow on this?

I would be very happy, if confirmation would NOT require saving any IP

Last edited by saccade (2018-05-23 11:22:45)

planeth · 2018-07-02 15:33:24

Controllers are free to develop methods to comply with this provision in a way that is fitting in their daily operations. At the same time, the duty to demonstrate that valid consent has been obtained by a controller, should not in itself lead to excessive amounts of additional data processing. This means that controllers should have enough data to show a link to the processing (to show consent was obtained) but they shouldn’t be collecting any more information than necessary.

This is straight from the “Article 29 Working Party Guidelines on consent under Regulation 2016/679”

Harvesting IP address clearly falls under “more information than necessary”. I think that the ICO also has some resources on the subject. Having a copy of the form —along with its version— where the consent was obtained and the version of the privacy notice attached to it should be sufficient.

saccade · 2020-07-10 18:27:29

Hi, I installed smd_access in a 4.8.1 install,
but I have no access to the plugin prefs.
“Prefs” leads to the advanced prefs, but the smd_access prefs do not appear there.

Last edited by saccade (2020-07-10 18:27:45)

saccade · 2020-09-22 15:23:50

Hi,
trying to install the plugin in an updated 4.8.3 install I cannot get it to work.
I have no access to prefs (panels prefs will be opened but no plugin related prefs shown,
but key generation is working.
I even get the key by com_connect/body_form,
but when using the link I always land at 404.

saccade · 2020-09-22 18:11:43

oops, I missed the section_mode-attribute which solved my 404s.
section_mode=“1” does it!

giz · 2023-03-08 01:21:53

Hello Stef

My install issue is duffrent to saccade’s above:

Installed smd_access_keys v1.1.0 on Textpattern v4.8.8 PHP version: 7.4.33: Install successful, database table created, preference pane works
Click on New Key, and nothing happens, other than a # being added to the url.

Do you have any advice on how I might find the cause? I can’t find anything amiss in my browser’s Web Inspector.

Thanks

giz · 2023-03-08 16:57:08

I get the same problem when I try the plugin on another 4.8.8 site.

Anyone?

Last edited by giz (2023-03-08 18:33:53)

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#121 2018-05-18 20:34:51

Re: smd_access_keys: secure, limited access to content

#122 2018-05-18 20:46:08

Re: smd_access_keys: secure, limited access to content

#123 2018-05-19 08:12:34

Re: smd_access_keys: secure, limited access to content

#124 2018-05-20 16:34:05

Re: smd_access_keys: secure, limited access to content

#125 2018-05-21 15:23:25

Re: smd_access_keys: secure, limited access to content

#126 2018-05-21 19:53:54

Re: smd_access_keys: secure, limited access to content

#127 2018-07-02 15:33:24

Re: smd_access_keys: secure, limited access to content

#128 2020-07-10 18:27:29

Re: smd_access_keys: secure, limited access to content

#129 2020-09-22 15:23:50

Re: smd_access_keys: secure, limited access to content

#130 2020-09-22 18:11:43

Re: smd_access_keys: secure, limited access to content

#131 2023-03-08 01:21:53

Re: smd_access_keys: secure, limited access to content

#132 2023-03-08 16:57:08

Re: smd_access_keys: secure, limited access to content

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