This page has been moved to docs.fsfe.org with the rest of the sysadmin documentation.
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.
Contents
Web sites : visitors
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal permission do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
FSFE website |
Users visiting the website |
Source IP addresses |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
Legitimate Interest |
System Hackers |
We store the data for 14 days |
FSFE website |
Signing the Upcycling Android open letter |
Email and name, country, ZIP code, comment |
To display signature of the open letter; |
Consent |
The public list is accessible to everyone |
The campaign's duration |
PMPC website |
Users visiting the website |
Source IP, Date, HTTP request, User-agent. |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
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 |
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 |
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 |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
Legitimate interest |
system administrators |
Data is stored for the container lifetime (? 2) |
Blogs |
User visiting the website |
IP addresses |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
Legitimate Interest |
(missing information 3) |
(missing information 3) |
Wiki |
User visiting the website |
Source IP addresses |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
Legitimate Interest |
Wikicare takers, system-hackers |
We store data for 14 days |
Project Call |
Contact information from this form |
Name, Email-Address, Local Group Name, Project Plan |
Get in contact about incoming requests |
Contract |
FSFE Council |
Data is stored for 6 months after the request |
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.]
Collaboration
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal permission do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Community Database and LDAP server |
FSFE account management |
Name, email address, username, password hash |
Managing access to FSFE's online services |
Legitimate interest |
Community database administrator |
Data is stored as long as the account exists |
Community data maintenance |
Birthday, sex, preferred language, postal address, secondary email address |
Managing FSFE's community of contributors |
Consent |
Community database administrator |
Data can be changed or deleted at any time by the subject |
|
Wiki |
FSFE Wiki |
Account data (Name or Username, Pseudonym, email address from the FSFE account, optionally jabber ID), a dedicated personal page (optional), attribution for all contributions |
Wiki management and attribution of work |
Contract |
Public pages are accessible to everyone, other pages may have limited access depending on ACL |
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 |
contribution are public, logs are accessible only to Service maintainers, system administrators |
As long as the account exist (to be confirmed 1) |
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 |
Reimbursements |
Financial reimbursements for expenses |
All communication around the reimbursement including payment data |
Reimbursing (paid and volunteer) contributors for their expenses |
Contract |
Financial team, parties involved in the payment processing, tax consultant, public authorities |
Data is stored according to statutory storage periods |
Orders
Processing |
What data is processed? |
Why is the data processed? |
What legal permission do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Promotion material orders |
Order information from this form |
Answering of incoming requests, sending packages, and requesting feedback |
Contract |
FSFE office staff and financial team |
Data is stored for 13 months after the order |
Generating statistics about promotion material orders |
Legitimate interest |
||||
Payment information in case a donation is made along with the order |
Accounting |
Legal requirements |
Financial team, parties involved in the payment processing, tax consultant, public authorities |
Data is stored according to statutory storage periods |
|
Merchandise orders |
Order information from this form |
Answering of incoming requests, and sending packages |
Contract |
FSFE office staff and financial team. |
Data is stored for 13 months after the order |
Payment information |
Accounting |
Legal requirements |
Financial team, parties involved in the payment processing, tax consultant, public authorities |
Data is stored according to statutory storage periods |
|
Registration for participation in FSFE events |
Information entered into each event registration form |
To organize each FSFE event |
Consent |
FSFE office staff and financial team |
Data is stored for 1 month after the end date of each FSFE event |
Payment information |
Accounting |
Legal requirements |
Financial team, parties involved in the payment processing, tax consultant, public authorities |
Data is stored according to statutory storage periods |
|
Registration for Legal Network membership |
Information entered into this form |
To determine eligibility for Legal Network membership |
Consent |
FSFE office staff, Legal Team |
Data is stored as long as the subject is a member of the Legal Network |
Donations
Processing |
What data is processed? |
Why is the data processed? |
What legal permission do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
All Donations |
Name, email address, date of payment, payment method, amount |
Processing the donation, accounting |
Legal requirements |
Community database administrator, financial team, parties involved in the payment processing, tax consultant, public authorities |
Data is stored according to statutory storage periods |
Supporter contributions |
Name, email address, date/method/amount of last payment, automatic renewal status |
Reminding supporters of the next contribution |
Contract |
Community database administrator |
Data is processed as long as the subject participates in FSFE's supporter program |
Donations for which a donation receipt is requested |
Name, postal address, date of payment, amount, date of donation receipt |
Issuing donation receipts |
Legal requirements |
Community database administrator, financial team, tax consultant, public authorities |
Data is stored according to statutory storage periods |
Donations >= 480 € per year or 40 € per month |
Name, donation category |
Maintaining the public donors list for reasons of transparency and recognition |
Consent |
This data is public |
As long as the FSFE exists or until the person revoke his or her consent |
Communications means
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal permission do we have according to Article 6 of GDPR? |
Who has access? |
What is our Data retention policy? |
Community emails |
Emails from the FSFE to its communiy |
Name, email address, preferred language (optional), sex (optional, to allow for correct grammar), postal address (optional, to allow for region-specific information) |
Keeping the FSFE community informed |
Consent |
Community database administrator |
Consent can at any time be revoked by the subject |
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, PR team |
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 the FSFE community
Service |
Processing |
What data is processed? |
Why is the data processed? |
What legal permission 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 |
|
|
|
|
|
|
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 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 permission 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 |
Weekly timelogs |
Communication weekly activities in encrypted mail |
Data about time spent on different activities |
To keep track of overtime and remaining vacation days |
Contract (employment/Intern contract) |
Mails encrypted to FSFE Council members |
Data should be deleted after accounting for the year is done. |
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 principles
- [DRAFT]
By default, we apply the following principles to assure the security of your data:
- we use only Free Software and open standards;
- we apply a need to know principle for all our processing;
- no password is in cleartext;
- we log the minimum amount of information to allow us to debug or assure the security of our system;
- we in general encourage staff and volunteers to use encryption for communication and file storage;
- very few people have access to servers where the data is stored
Newsletter / Press releases
Service
Processing
What data is processed?
Why is the data processed?
What legal permission 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 permission 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
-
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
Webserver + build system
Webserver