Differences between revisions 41 and 92 (spanning 51 versions)

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

FSFE Records of processing activities

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
PMPC website	Users visiting the website	Source IP, Date, HTTP request, User-agent. The source IP is the IP address of our reverse proxy, not a personnal 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	Sysadmin	The campaign's duration (to be confirmed 1)
PMPC website	Signing the open letter	Email and name, country, ZIP code, comment Italic information is voluntary	To display signature of the open letter; to give updates about the campaign(specific consent) To add the signature to the public list(specific consent)	Consent Link to privacy policy	The public list is accessible to everyone PMPC coordinator and Sysadmin for others information	The campaign's duration
art13 savecodeshare.eu	Signing the open letter	Name, email, country Italic information is voluntary	To display signature of the open letter; to give updates about the campaign (specific consent)	Consent Link to privacy policy	Signatures will be handed over to the Members of the European Parliament and the EU Council Sysadmin access everything	Data is stored for the container lifetime (i.e. the campaign's duration) Data may be kept by the Members of the European Parliament and the EU Council for an unknown time
art13 savecodeshare.eu	Visiting the website	IP addresses, SQL statements for error messages contain personal information The IP is the IP address of our reverse proxy, not a personnal 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

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 Database and LDAP server	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) As the account is the base to attribution of contribution, we do not delete account without the data subject request.
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) As the account is the base to attribution of contribution, we do not delete account without the data subject request. 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
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
	Order information from this form	Generating statistics about promotion material orders	Legitimate interest	FSFE office staff and financial team	Data is stored for 13 months after the order
	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
Merchandise orders	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
Registration for participation in FSFE events	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 It may imply to enforce sanction like banishment of mailing-list or events	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 sysadmin	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).

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

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

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-= FSFE Data processing =
+#acl Group/Team:read,write,delete,revert,admin All:read
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-The goal of this page is to provide information regarding data processing at FSFE.
+= 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.
-Line 5:
+Line 6:
-||'''Service'''||'''What data is processed?'''||'''Why is the data processed?'''||'''What legal authorization do we have according to [[https://gdpr-info.eu/art-6-gdpr/|Article 6]] of GDPR?'''||'''Who has access?'''||'''What is our Data retention policy?'''||
||Account Managing Software (AMS)||Only that which is included in the community database no separate information.|| - || - || - || - ||
|| art13 savecodeshare.eu|| 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 || consent [[https://wiki.fsfe.org/Activities/Privacy/PolicyDraft/Art13|Link to privacy policy]] || system administrators || Data is stored for the container lifetime ||
||Blogs|| ||Error message are used for debugging, the web server needs to know the source IP address|| || || ||
||Community Database||Data for our donors, 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, information about donations transferred, information about automatic donation renewal status, information about donation receipts issued, ''username and password (hashed) for FSFE services'', information about fellowship cards received, data modification history. ''Italic'' information is voluntary.||(1) Donor liaison, including the creation of donation receipts.<<BR>>(2) Sending out information emails to those who opted in.<<BR>>(3) Maintenance of access to FSFE's online services.<<BR>> (4) Statistical queries.||(1) Legal requirements and legitimate interest.<<BR>>(2) Explicit consent.<<BR>>(3) ?<<BR>>(4) Legitimate interest.||Community database administrator (currently: Reinhard), system administrators.||Data is automatically deleted if the registration is not confirmed (through payment of a donation or through approval by a team coordinator) within 6 weeks after signup. Upon explicit request, data is anonymised.||
||Discourse||IP Addresses, post timings, usernames|| IP addresses are collected by discourse to prevent and block spam|| Consent || system administrators + service maintainers || Data is stored for the container lifetime ||
||DNS|| 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 ||
||Docker environment||Docker containers activities. No personal data|| - || - || - || - ||
||docker status service||Docker containers activities. No personal data|| - || - || - || - ||
||Drone||Building scripts. No personal data|| - || - || - || - ||
||Finance accounting||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||Financial team, tax consultant, legal authorities.||Currently none defined. Data must be kept at least 10 years by law.||
||Finance repo|| IP Addresses + username logging || debugging purposes || consent || Albert, Francesca, Matthias, Max, Polina, Ulrike || 1 month ||
||Forms API|| No personnal 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 ||
||Friendica|| || || || || ||
||GDPR process|| || || || || ||
||Gitea||Emails and usernames of registered users and the files they work with; webserver logs (source IPs)||For authentication and operation of the platform; webserver logs for debugging || Consent || Service maintainers, system administrators || None; 1 week for logs ||
||IRC Cloaks|| || || || || ||
|| Jabber / XMPP || 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 || system administrators || 2 weeks ||
|| LDAP || 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|| 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 || Nothing is stored ||
|| Link shortener|| || || || || ||
|| Email || 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 ||
||Mailing lists || Email address, full name (if the person choose to insert it), subscription details, logging see Mail and the [[https://wiki.list.org/DOC/What%20log%20files%20%28logs%29%20does%20Mailman%20write|official Mailman page]] || The mailing list service needs to know email addresses to achieve its goal || Consent || ADMIN-TECH,List-Admins,team@ || 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 ||
||Mailtrain + ZoneMTA|| Email address, full name, subscription details || || || || Data is stored for the container lifetime ||
||Nextcloud|| Emails and usernames of registered users and the files they work with; calendar and contact entries; webserver logs (user agent)||Proposer operation of service; debugging || Consent || Service maintainers, system administrators || Data: unlimited / until user deletes data; logs: until service update ||
||Nlformat script|| || || || || ||
||OpenVPN|| || || || || ||
||OTRS||All communication around the tickets, in the format of emails exchanged<<BR>> Internship applications are stored as OTRS tickets<<BR>> We store promo orders information from [[https://fsfe.org/contribute/spreadtheword|this]] form ||Answering of incoming requests.|| Consent ||All members of the team which is responsible for the kind of request.||None.||
||Personell management|| || || || || ||
||Planet|| || || || || ||
||PMPC website|| Source IP, Date, HTTP request, User-agent|| To display signature of the open letter and to give updates about the campaign || consent. [[https://publiccode.eu/privacy/|Link to privacy policy]] || Sysadmin || The campaign's duration ||
||Registration system||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.||Ulrike + Polina + ? + System administrators||None defined yet.||
||SSL certificates || 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 ||
||Subversion || 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 || - ||
||Webserver + build system|| || || || || ||
||FSFE website|| Per diem calculator (used for travels reimbursement). The data is only processed, not stored || To help staffers to calculate allowance || Consent || Website administrators || The data is not stored||
||Wekan||Technical logs, no personal data|| - || - || - || - ||
||Wiki|| Source IP addresses || Debugging and security purposes || ||Wikicare takers, system-hackers || We store data for 14 days||
+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 [[https://fsfe.org/contact/contact.html|contact]] page.

<<TableOfContents(2)>>

-------

== Web sites : visitors ==
 
   
|| '''Service''' ||'''Processing'''||'''What data is processed?'''||'''Why is the data processed?'''||'''What legal permission do we have according to [[https://gdpr-info.eu/art-6-gdpr/|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 ||
|| PMPC website || Users visiting the website|| Source IP, Date, HTTP request, User-agent.<<BR>>The source IP is the IP address of our reverse proxy, not a personnal 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 || Sysadmin || The campaign's duration (to be confirmed 1)||
|| PMPC website || Signing the open letter || Email and name, ''country, ZIP code, comment'' <<BR>> ''Italic'' information is voluntary|| To display signature of the open letter; <<BR>> to give updates about the campaign(specific consent) <<BR>> To add the signature to the public list(specific consent) || Consent <<BR>> [[https://publiccode.eu/privacy/|Link to privacy policy]] || The public list is accessible to everyone <<BR>> PMPC coordinator and Sysadmin for others information || The campaign's duration ||
|| art13 savecodeshare.eu || Signing the open letter || Name, email, ''country'' <<BR>> ''Italic'' information is voluntary|| To display signature of the open letter; <<BR>> to give updates about the campaign (specific consent) || Consent <<BR>> [[https://wiki.fsfe.org/Activities/Privacy/PolicyDraft/Art13|Link to privacy policy]] || Signatures will be handed over to the Members of the European Parliament and the EU Council <<BR>> Sysadmin access everything || Data is stored for the container lifetime (i.e. the campaign's duration) <<BR>> Data may be kept by the Members of the European Parliament and the EU Council for an unknown time ||
|| art13 savecodeshare.eu || Visiting the website || IP addresses, SQL statements for error messages contain personal information <<BR>>The IP is the IP address of our reverse proxy, not a personnal 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||


== 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 [[https://gdpr-info.eu/art-6-gdpr/|Article 6]] of GDPR?'''||'''Who has access?'''||'''What is our Data retention policy?'''||
||<rowspan="2"> 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  <<BR>> || Wiki management and attribution of work || Contract || Public pages are accessible to everyone, other pages may have limited access depending on [[https://wiki.fsfe.org/TechDocs/Wiki)|ACL]] || As long as the account exist (to be confirmed 1) <<BR>> As the account is the base to attribution of contribution, we do not delete account without the data subject request.||
|| 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) <<BR>> As the account is the base to attribution of contribution, we do not delete account without the data subject request. <<BR>> <<BR>> 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 ||
|| 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 [[https://gdpr-info.eu/art-6-gdpr/|Article 6]] of GDPR?'''||'''Who has access?'''||'''What is our Data retention policy?'''||
||<rowspan="3"> Promotion material orders ||<rowspan="2"> Order information from [[https://fsfe.org/contribute/spreadtheword|this]] form || Answering of incoming requests, sending packages, and requesting feedback || Contract ||<rowspan="2"> FSFE office staff and financial team ||<rowspan="2"> 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 ||
||<rowspan="2"> Merchandise orders || Order information from [[https://fsfe.org/order/order|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 ||
||<rowspan="2"> 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 [[https://fsfe.org/activities/ftf/ln-application.en.html|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 [[https://gdpr-info.eu/art-6-gdpr/|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 [[https://fsfe.org/donate/thankgnus.en.html|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 [[https://gdpr-info.eu/art-6-gdpr/|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 [[https://wiki.list.org/DOC/What%20log%20files%20%28logs%29%20does%20Mailman%20write|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 <<BR>> It may imply to enforce sanction like banishment of mailing-list or events || 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 [[https://gdpr-info.eu/art-6-gdpr/|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 <<BR>> sysadmin || 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 [[https://gdpr-info.eu/art-6-gdpr/|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 || [[https://fsfe.org/internal/pd|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).||

{{{#!wiki comment/dotted

== Newsletter / Press releases ==

|| '''Service''' ||'''Processing'''||'''What data is processed?'''||'''Why is the data processed?'''||'''What legal permission do we have according to [[https://gdpr-info.eu/art-6-gdpr/|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 [[https://gdpr-info.eu/art-6-gdpr/|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 || || || || || ||}}}


== 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

Diff for "TechDocs/DataProcessingTransparency"