phpList and privacy, the GDPR framework
Ok, ok you probably do not want to hear about privacy, but trust us when we deal with emailing privacy is really important as it is one of the most visible part that an internet user is seeing from an organization.
Probably you already hate a lot of organization because they are sending you or sent you in the past some emails you did not give your consent for. So that's the main reason why we are going to take privacy seriously here.
In order to deal with privacy we are going to take the GDPR framework. Of course it is not the perfect solution but GDPR is offering a complete view of privacy that I think fit will fit the scope of this course.
So, under GDPR, the owner of an information system needs to respect the rights of the data subject, let's see below what are those rights and how phpList complies with those (by the way all Free software respect GDPR somehow as they are all customizable):
- Right of access: a data subject needs to be able to access to the personal data you are collecting about her/him. So here it raise the issue of how to identify this person. I suggest that you check her/his identity by sending an email to this person in order to ensure that her/him is really the one she/he claims to be. Once done go to the subscribers category -> Search subscribers -> Click on a subscriber -> Click on download subscriber data. You can then send those data to your data subject. As a result it is also filling the needs of the right of data portability.
- Right of rectification: a typical example, the data subject is tired of receiving an emailing where her/his first name is not spelled right. Then she/he has the right to ask you to correct this out. Just go to subscribers category -> Search
subscribers -> Click on a subscriber -> Correct the attribute which is concerned.
- Right of erasure: typical use case, "I don't want to hear about your company anymore", this is different from unsubscribing. Unsubscribing means that the data subject do not want to receive email for this specific list/reason she/he gave you the consent for. Right of erasure means everything about the data subject. To apply this right: go to subscribers category -> Search subscribers -> Click on a subscriber -> Remove subscriber. It will display a message "Are you sure you want to remove this subscriber from the system?" which mean what it means, totally deleted from the information system.
- Right to restrict the processing: I love this right. It is like "hold on, you are doing something bad here, so stop playing with my data but don't delete them as I will contact authorities to audit you." So here it means that you cannot play with the data, so the best thing here is to unsubscribe the data subject from all the lists that she/he subscribed to. Go to subscribers category -> Search subscribers -> From there you will have a garbage icon in order to remove all the lists to which this data subject subscribed to. Note that within the subscriber profile page you will see who is the one who performed this action. So you can ensure this way that you were the one who performed this action and not the data subject.
- Right to data portability: we already mentioned this part within the right of access.
- Right to object: the right to object can be applied so as the restrict of processing the data in our case. As far as the data subject unsubscribe you cannot process his personal data until she/he game back consent to you. Go to subscribers category -> Search subscribers -> Click on the garbage icon. Note that for convenience you can also ask them to just click on unsubscribe.
- Automated individual decision-making, including profiling: phpList is not concerned here.
Even if rights are the cornerstone of GDPR, GDPR is also about:
- Awareness within your organization: here the best thing is to train your staff about GDPR. Clearly the key thing is to explain that your staff should not mess up with the data of your consumers.
- Security: as you are playing with personal data you need to secure your phpList instance, it includes many things: ssl, strong passwords, log connection of your own users, policy about bring your own devices...