Privacy Report

Introduction

We hold personal data about people submitting reviews, moderators, and people accessing the ODRS service for a variety of purposes. This policy sets out how we seek to protect personal data and ensure that people understand the rules governing their use of personal data. In particular, this policy requires that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Scope

This policy applies to all users who have access to any of the personally identifiable data.

Who is responsible for this policy?

As the Data Protection Officer, Richard Hughes has overall responsibility for the day-to-day implementation of this policy. The DPO is registered with the Information Commissioner’s Office (ICO) in the United Kingdom as a registered data controller.


Our Procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening, or where such collection is unavoidable and/or considered pragmatic in the context, e.g. logging the number of upvotes of a specific review.

We do not consider an IP address requesting the application ratings data to represent a single user (due to NAT or VPN use), and as such requests are not considered personal data using the draft GDPR guidelines.

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this. Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should inform the DPO.

Your personal data

You must take reasonable steps to ensure that personal data we hold about moderators is accurate and updated as required. For example, if your personal circumstances change, please update them using the profile pages or inform the Data Protection Officer.

Data security

We keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.

Storing data securely

All data is stored electronically and all passwords are stored adhering to security best practices.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines. Anonymized statistics (e.g. review requests) will be kept for a maximum of 5 years which allows us to project future service requirements and provide usage graphs over time.

Transferring data internationally

There are restrictions on international transfers of personal data. We do not transfer personal data anywhere inside or outside the EU without the approval of the Data Protection Officer, unless required to do so by law.


Subject Access Requests

Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.

On receiving a subject access request, we will refer that request immediately to the DPO. We may ask you to help us comply with those requests. Please also contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with your rights

We will never use identifiable vendor data for direct marketing purposes.


GDPR Provisions

Where not specified previously in this policy, the following provisions will be in effect on or before 25 May 2018.

Privacy Notice - transparency of data protection

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our project. The following are details on how we collect data and what we will do with it:

Moderator Information

What: The moderator real name, password, and supported languages.
Why collected: Secure authentication, to allow moderators to log in an edit or delete reviews.
Where stored: MySQL database on odrs.gnome.org.
When copied: Backed up to off-site secure storage weekly.
Who has access: The ODRS administrators and the DPO.
Wiped: When the moderator requests deletion of the user account.

Service Event Log

What: IP address (unhashed) and REST method requested, along with any error.
Why collected: Providing an event log for showing service problems.
Where stored: MySQL database on odrs.gnome.org.
When copied: Backed up to off-site secure storage weekly.
Who has access: The administrator and the DPO.
Wiped: After 5 years.

User Votes and Karma

What: User ID (hashed), timestamp, access time, karma and votes cast.
Why collected: To know what users have voted on each review, and to prevent abuse by users down or upvoting too many things.
Where stored: MySQL database on odrs.gnome.org.
When copied: Backed up to off-site secure storage weekly.
Who has access: The administrator and the DPO.
Wiped: After 5 years.

Application Review

What: Date created, application ID, locale, review summary, review content, user hash, user IP address (hashed), displayed user name, application version, distibution, chosen star rating.
Why collected: Stores the user-supplied review to be shared .
Where stored: MySQL database on odrs.gnome.org.
When copied: Backed up to off-site secure storage weekly.
Who has access: The administrator and the DPO has access to all fields, anonymous users can access all except the user hash and IP address, although some are masked and only used for sorting (e.g. distro and version).
Wiped: When the review is deleted.

We will ensure any use of personal data is justified using at least one of the conditions for processing and this had been specifically documented above.

Consent

The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time. Revoking consent to use data means any provided reviews will be deleted.

Data portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format, typically an SQL export. These requests should be processed within one month, provided there is no undue burden and it does not compromise the odrs_privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This is available for free.

Right to be forgotten

A user may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies. Users will need to provide the either their IP address or user hash used when creating the review.

Privacy by design and default

Privacy by design is an approach to projects that promote odrs_privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all changes commence with a odrs_privacy plan. When relevant, and when it does not have a negative impact on the data subject, odrs_privacy settings will be set to the most private by default.

Reporting breaches

All users of the ODRS have an obligation to report actual or potential data protection compliance failures. This allows us to:

  • Investigate the failure and take remedial steps if necessary
  • Maintain a register of compliance failures
  • Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures

Please refer to the DPO for our reporting procedure.

Monitoring

Everyone who actively uses the ODRS must observe this policy. The DPO has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.


Consequences of Failing to Comply

We take compliance with this policy very seriously. Failure to comply puts both you and us at risk. If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.