FSFE Records of processing activities
The goal of this page is to provide information regarding data processing at FSFE. It is still a work in progress and we are constantly improving the information. In case you have any questions about it, please get in contact with privacy@fsfe.org.
The FSFE e.V., Schönhauser Allee 6/7 Stairway 2, 5. floor 10119 Berlin Germany, is controller for all those processings, the most effective ways to contact the association are on our contact page.
Web sites : visitors
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
FSFE website |
Users visiting the website |
?? |
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PMPC website |
Users visiting the website |
Source IP, Date, HTTP request, User-agent |
The web server needs the public IP addresses to serve requests |
Legitimate Interest |
Sysadmin |
The campaign's duration (to be confirmed 1) |
PMPC website |
Signing the open letter |
Email and name, country, ZIP code, comment |
To display signature of the open letter; |
consent Link to privacy policy |
The public list is accessible to everyone |
The campaign's duration |
art13 savecodeshare.eu |
Signing the open letter |
Name, email, country |
To display signature of the open letter; |
consent Link to privacy policy |
Signatures will be handed over to the Members of the European Parliament and the EU Council |
Data is stored for the container lifetime (i.e. the campaign's duration) |
art13 savecodeshare.eu |
Visiting the website |
IP addresses, SQL statements for error messages contain personal information |
Error message are used for debugging, the webserver needs to know the source IP address |
Legitimate interest |
system administrators |
Data is stored for the container lifetime (? 2) |
Blogs |
User visiting the website |
IP addresses |
Error message are used for debugging, the web server needs to know the source IP address |
Legitimate Interest |
(missing information 3) |
(missing information 3) |
Wiki |
Webserver |
Source IP addresses |
Debugging and security purposes |
Legitimate Interest |
Wikicare takers, system-hackers |
We store data for 14 days |
Social Media
If you do not click on any external buttons to external sides, data will not be transferred. [TODO : Add references to privacy policies of the services we use.]
Contributing to FSFE
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Webserver + build system |
Webserver |
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Wiki |
FSFE Wiki |
Account data (Name, Pseudonym, email address from the supporter account, optionally jabber ID), a dedicated supporter page (optional), attribution for all contributions |
Wiki management and attribution of work |
Contract of services or Consent (to be confirmed) |
Public pages are accessible to everyone, other pages may have limited access depending on ACL (cf. https://wiki.fsfe.org/TechDocs/Wiki) |
As long as the account exist (to be confirmed 1) |
Gitea |
FSFE Gitea contributions |
Emails and usernames of registered users and the files they work with; webserver logs (source IPs) |
For authentication and operation of the platform; attribution of contribution; webserver logs for debugging |
Contract of services or Consent (to be confirmed) |
contribution are public, logs are accessible only to Service maintainers, system administrators |
Contribution is kept as long as the account exists (to be confirmed 2); 1 week for logs |
FSFE website |
Translators of the website |
name or pseudonym of translators of each page |
To attribute translation to its translators whenever they accept to be cited |
consent |
public information |
Attribution is kept as long as the translation exist |
Orders
OTRS |
Promo orders |
We store promo orders information from this form |
Answering of incoming requests and sending packages |
Consent |
FSFE office staff and finance team. |
The time to send the requested promotional documents and, if needed, checking that it arrived. (to be confirmed 1) |
OTRS |
Merchandise orders |
We store merchandise orders information from this form |
Answering of incoming requests and sending packages |
Consent |
FSFE office staff and finance team. |
The time to send the requested merchandise plus, if needed, checking that it arrived. (to be confirmed 2) |
Supporter/Donor handling
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Community Database |
Donations |
Data regarding our donors: information about donations transferred, automatic donation renewal status, donation receipts issued, emails if opted in |
Donor liaison, including the creation of donation receipts. |
Legal requirements |
Community database administrator, system administrators. |
(To be confirmed 1) 10 years the data necessary for accounting; as long as you are a donor plus 1 year for data allowing us to contact you; as long as you don’t opted out, the data to automatically renew your donation if you asked for it. |
Community Database |
Emails of donors |
emails if opted in |
Donor liaison, including the creation of donation receipts. |
Consent |
Community database administrator, system administrators. |
none |
FSFE website |
All data showed in thankgnus*.xhtml |
To display a list of our donors, to respect our transparency commitment and thanks our donors |
Consent |
This data is public |
As long as the FSFE exist or until the person revoke his or her consent |
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Community Database |
Supporters account |
Data for our, supporters, staff, contractors, and volunteers: registration status, blacklisting status, name, birthday, sex, preferred language, postal address, primary and secondary email address, opt-in information for communication, username and password (never in clear-text) for FSFE services, information about fellowship cards received, data modification history. Italic information is voluntary. |
Supporter management |
Consent for supporters and volunteers |
Community database administrator, system administrators. |
Data is automatically deleted if the registration is not confirmed (through approval by a team coordinator) within 6 weeks after signup. Upon explicit request, data is anonymised. |
Communications means
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Mailman |
Mailing lists (https://lists.fsfe.org/mailman/listinfo) |
Email address, full name or pseudonym (if the person choose to insert one), subscription details, logging see the official Mailman page |
To manage the mails going from and to the list the individual subscribed to. |
Consent (for each mailing list) |
Mails on the mailing list may have different level of publicity from public (archive included) to restricted to a given group (see description of the list for more information) <BR> ADMIN-TECH,List-Admins,team@ may have access to all mails |
Posts and subscriptions are stored for 1 year, bounces and errors are stored for 1 month, messages sent by Mailman itself are stored for 1 week, digests are stored for 4 months |
QuickML |
Mailing list |
Email addresses |
To manage the mails going from and to the list the individual subscribed to. |
Consent (for each mailing list) |
?? |
?? |
Newsletter |
Newsletter |
Email addresses, preferred language |
To send the newsletter in the good language |
Consent |
Sysadmin |
As long as subscribed. |
OTRS |
Tickets processing |
All communication around the tickets, in the format of emails exchanged |
Answering of incoming requests. |
Consent |
FSFE core team. |
The time to close the issue raised + X months (To Be determined 1) |
Discourse |
Webserver |
IP Addresses, post timings, usernames, posts |
IP addresses are collected by discourse to prevent and block spam |
Consent |
system administrators + service maintainers |
Data is stored for the container lifetime |
CARE Team |
CoC and sanction management (To be confirmed 2) |
Depending on the situation, identification data (name/pseudo/description), contact (emails, phone number) etc. |
Data are processed to solve CoC infringement |
Legitimate interest |
CARE Team |
The time needed to solve the situation. Information regarding blacklisted individuals are kept for the time of the sanction. |
Communications tools for Supporters
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Email server |
Emails processing and forwarding |
Email addresses + logs (send, receive emails, hostnames, IP addresses of messages sent through SMTP, etc) |
To manage the forward email service and assure a basic level of spam control |
Consent for providing emails and legitimate interest for spam control |
Albert Jonas Matthias Max Paul fellowship@klaproth |
1 month |
IRC Cloaks |
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Jabber / XMPP |
Massage processing |
Account rosters, logs (connect, disconnect, messages process and possibly stored temporally on the server (offline storage + muc preview), status messages, with debug logging up to who talks to whom) |
Debugging purposes |
Consent for accessing the service |
system administrators |
2 weeks |
Blogs |
Writing your blog |
Your account (Username, nickname, email addresses, more is optional), your articles, log data |
To provide a platform for our supporter's blogs |
Contract |
article publicity depends on the owner choosing |
Until you delete your blog or we discontinue the service |
Employee information and tools
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal authorization do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Finance Archive |
Storage of financial and employee records |
Transaction data from all bank accounts, includes names of all people who send or receive money to/from FSFE. |
To do our accounting |
Legal requirements (we have to keep them for 10 years by law) |
Financial team, tax consultant, legal authorities. |
Information older than X>10 (11?) years are deleted after the annual closure of our accounts (to be confirmed 2) |
Finance Archive |
(not an independent processing) |
SSH connections are logged (IP Addresses + username) |
for debugging and security purposes |
not applicable (not an independent processing) |
coordinator and deputy coordinator system administration team , finance team |
1 month |
FSFE website |
Per diem calculator (used for travels reimbursement) |
The data entered in the form |
To help staffers to calculate allowance |
Contract (employment/Intern contract) |
Website administrators can access log (to be confirmed 1) |
The data is not stored |
Nextcloud |
Nextcloud Account management |
Emails and usernames of registered users and the files they work with; calendar and contact entries; webserver logs (user agent) |
Main working tool for everyday tasks (from sharing documents to calendar and conatact management) |
Contract (employment/Intern contract) |
Service maintainers, system administrators |
account: (missing information 3) Data: unlimited / until user deletes data; logs of data: until service update |
Nextcloud |
(not an independent processing) |
webserver logs (user agent) |
Security and debugging |
not applicable (not an independent processing) |
Service maintainers, system administrators |
logs: until service update |
OTRS |
Job and internship applications |
Job and internship applications are stored as OTRS tickets, after a decision the ticket with attachments will be deleted |
Answering and reviewing applications |
Consent |
FSFE council members and staff. We may share the application with advisors and members |
(missing information 4). |
Security principle
- [DRAFT]
By default, we apply the following principles to assure the security of your data:
- we apply a need to know principle for all our processing;
- no password is stored in clear;
- we log the minimum amount of information to allow us to debug or assure the security of our system.
Newsletter / Press releases
Service
Processing
What data is processed?
Why is the data processed?
What legal authorization do we have according to Article 6 of GDPR?
Who has access?
What is our Data retention policy?
Newsletter and Press lists
Information about who did what including names and where things happened
To inform the public about Free Software
Nlformat script
Misc
Service
Processing
What data is processed?
Why is the data processed?
What legal authorization do we have according to Article 6 of GDPR?
Who has access?
What is our Data retention policy?
DNS
DNS queries
Logging IP Addresses for errors and for example denied queries, more if debug logging is temporary necessary. With debug logging disabled the DNS queries are not stored, only processed
Legal obligation
Debugging purposes
System administrators
1 month
SSL certificates
Certificate processing (openssl)
Personal information of the person requesting them, email addresses and names (or whatever data is inserted by the person who is doing the certificate request)
Because the CA needs to know who requested a certificate
Consent
System administrators
Data are stored as long as the certificate exists
OpenVPN
Personell management
Subversion
svn use
No personal information are stored. Public IP addresses are processed by the webserver
The webserver needs the public IP addresses to serve requests
Consent
System administrators
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Registration system
Data entered in surveys
Can be configured per event. For LLW, it is name, email address, affiliation, position, telephone number, ticket type, postal address, VAT Id, promotion code used, information about dinner attendance, dieatary preferences (!), participation in mentor system.
Necessary to organise the event.
Fulfillment of a contract.
finance team + + System administrators
None defined yet.
LDAP
Authentication and queries
ldap queries are logged to syslog (we log who tries to login on what service and when)
Security and debugging purposes
consent
System administrators
1 month
Limesurvey
Webserver
Public IP addresses are processed by the web server
The web server needs the public IP addresses to serve requests
Consent
System administrators
Nothing is stored
Link shortener
Planet
Emails processing
Forms API
No personal data stored in the logs, but the service processes emails
The service needs the email of the users submitting a form so the emails can reach them
Consent
system administrators
Data is stored for the container lifetime
|| Mailtrain + ZoneMTA || Emails processing || Email address, full name, subscription details || || || || Data is stored for the container lifetime ||