|
Size: 12195
Comment: Fix typo
|
Size: 21108
Comment:
|
| Deletions are marked like this. | Additions are marked like this. |
| Line 3: | Line 3: |
| = FSFE Data processing = | = 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: |
| 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 [[https://fsfe.org/contact/contact.html|contact]] page. |
| Line 7: | Line 8: |
| == Web sites == | == Web sites : visitors == || '''Service''' ||'''Processing'''||'''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?'''|| || FSFE website || Users visiting the website|| ?? || The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes || Legitimate Interest || || || || 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 == |
| Line 10: | Line 29: |
| || Webserver + build system|| Webserver || || || || || || || 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 || Consent || Website administrators || The data is not stored|| || FSFE website || [[https://fsfe.org/donate/thankgnus.en.html|Donors page]] || All data stored in [[https://git.fsfe.org/FSFE/fsfe-website/src/branch/master/donate|thankgnus*.xhtml]] || To display a list of our donors || Consent || This data is public || None || || Wiki || Webserver || Source IP addresses || Debugging and security purposes || ||Wikicare takers, system-hackers || We store data for 14 days|| || art13 savecodeshare.eu || Webserver || 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 || || Gitea || Accounts management || 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 || || Gitea || Webserver || web server logs (source IPs)|| ogs for debugging || Consent || Service maintainers, system administrators ||1 week for logs || || Link shortener || || || || || || ||Planet || || || || || || || || PMPC website || Users visiting the webiste|| Source IP, Date, HTTP request, User-agent|| The web server needs the public IP addresses to serve requests || Consent. [[https://publiccode.eu/privacy/|Link to privacy policy]] || Sysadmin || The campaign's duration || || PMPC website || Signing the open letter || Email and name, country, ZIP code, comment || 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 || || Blogs || User visiting the website|| || Error message are used for debugging, the web server needs to know the source IP address|| || || || || == Supporter/Donor handling == || '''Service''' ||'''Processing'''||'''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?'''|| ||Community Database|| Donations || Data for our donors: information about donations transferred, information about automatic donation renewal status, information about donation receipts issued, emails if opted in|| Donor liaison, including the creation of donation receipts.||Legal requirements ||Community database administrator, system administrators.|| None || ||Community Database || Emails of donors || emails if opted in|| Donor liaison, including the creation of donation receipts.|| Consent ||Community database administrator, system administrators.|| none || ||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 (hashed) for FSFE services, information about fellowship cards received, data modification history. ''Italic'' information is voluntary.|| Maintenance of access to FSFE's online services.<<BR>> Statistical queries.|| Consent||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.|| |
||<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 || |
| Line 32: | Line 38: |
| || OTRS || Promo orders|| We store promo orders information from [[https://fsfe.org/contribute/spreadtheword|this]] form ||Answering of incoming requests and sending packages|| Consent ||FSFE office staff and finance team.||None|| || OTRS || Merchandise orders|| We store merchandise orders information from [[https://fsfe.org/order/order.html|this]] form ||Answering of incoming requests and sending packages|| Consent ||FSFE office staff and finance team.||None|| |
||'''Processing'''||'''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?'''|| ||<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 annual Legal and Licensing Workshop (LLW) || Information entered into each LLW registration form || To organize each LLW || Consent || FSFE office staff and financial team || Data is stored for 1 month after the end date of each LLW || || 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 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?'''|| || 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 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?'''|| || 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. || |
| Line 36: | Line 68: |
| == Communications == | == Communications tools for the FSFE community == |
| Line 40: | Line 72: |
| || Mailman || Maing 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 || || 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 || || OTRS || Tickets processing || All communication around the tickets, in the format of emails exchanged || Answering of incoming requests.|| Consent ||FSFE core team.||None.|| || Discourse || Webserver||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 || ||Friendica|| || || || || || |
|
| Line 47: | Line 73: |
| || 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 || system administrators || 2 weeks || | || 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 || |
| Line 49: | Line 76: |
== Employee information == |
== Employee information and tools == |
| Line 53: | Line 79: |
| ||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||Financial team, tax consultant, legal authorities.||Currently none defined. Data must be kept at least 10 years by law.|| ||Finance Archive|| SSH connections || IP Addresses + username logging | debugging purposes || consent || coordinator and deputy coordinator system administration team , finance team|| 1 month || || Nextcloud || Nextcloud Account management || 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 || || Nextcloud || Webserver || webserver logs (user agent) ||Proposer operation of service; debugging || Consent || Service maintainers, system administrators || Data: unlimited / until user deletes data; 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||None.|| |
||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 |
| Line 65: | Line 95: |
| == Social Media == Normally, if you do not click on any external buttons to external sides, data will not be transferred. Add references to privacy policies of the services do we use. |
|
| Line 83: | Line 108: |
| || 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 |
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 |
?? |
The web server needs the public IP addresses to serve the pages, we also use those data for debugging and security purposes |
Legitimate Interest |
|
|
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 |
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 authorization 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 authorization 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 annual Legal and Licensing Workshop (LLW) |
Information entered into each LLW registration form |
To organize each LLW |
Consent |
FSFE office staff and financial team |
Data is stored for 1 month after the end date of each LLW |
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 authorization 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 authorization 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 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 |
|
|
|
|
|
|
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 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 |
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