Go to main content

Textpattern CMS support forum

You are not logged in. Register | Login | Help

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

jakob
Admin
From: Germany
Registered: 2005-01-20
Posts: 3,946
Website

Re: smd_access_keys: secure, limited access to content

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.


TXP Builders – finely-crafted code, design and txp

Offline

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

saccade
Plugin Author
From: Neubeuern, Germany
Registered: 2004-11-05
Posts: 494

Re: smd_access_keys: secure, limited access to content

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?

Offline

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

jakob
Admin
From: Germany
Registered: 2005-01-20
Posts: 3,946
Website

Re: smd_access_keys: secure, limited access to content

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.


TXP Builders – finely-crafted code, design and txp

Offline

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

Bloke
Developer
From: Leeds, UK
Registered: 2006-01-29
Posts: 9,789
Website

Re: smd_access_keys: secure, limited access to content

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?


The smd plugin menagerie — for when you need one more gribble of power from Textpattern. Bleeding-edge code available on GitHub.

Txp Builders – finely-crafted code, design and Txp

Offline

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

giampablo
Member
From: Italy
Registered: 2008-07-17
Posts: 86
Website

Re: smd_access_keys: secure, limited access to content

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 :(

Offline

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

saccade
Plugin Author
From: Neubeuern, Germany
Registered: 2004-11-05
Posts: 494

Re: smd_access_keys: secure, limited access to content

(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)

Offline

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

planeth
Plugin Author
From: Nantes, France
Registered: 2009-03-19
Posts: 199
Website

Re: smd_access_keys: secure, limited access to content

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.

Offline

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

saccade
Plugin Author
From: Neubeuern, Germany
Registered: 2004-11-05
Posts: 494

Re: smd_access_keys: secure, limited access to content

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)

Offline

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

saccade
Plugin Author
From: Neubeuern, Germany
Registered: 2004-11-05
Posts: 494

Re: smd_access_keys: secure, limited access to content

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.

Offline

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

saccade
Plugin Author
From: Neubeuern, Germany
Registered: 2004-11-05
Posts: 494

Re: smd_access_keys: secure, limited access to content

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

Offline

Board footer

Powered by FluxBB