GDPR, privacy and plugins sending the information to external entities

GDPR, privacy and plugins sending the information to external entities

by Tomasz Muras -
Number of replies: 1
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Hello,

We have privacy API in Moodle, which covers data requests and deletion - good.

What we do not have covered, in terms of managing user's data is the situation where a plugin sends data externally.

If I host Moodle platform, I must inform my users how their data is being used. If I install a plugin, that sends user's data externally, I should really know about it. I should know:

* what data is being sent

* where is it sent (because of the GDPR it's important to know if it's sent within EU or outside)

Such an information is usually missing in plugin's description and the only way to find out about it, is to review the code of the plugin. Let's take an example - integration with an external service, which may be quite common: https://moodle.org/plugins/block_iprbookshop_ru . The block send the following information:

* user id
* first name
* last name
* email address

to the server outside EU (http://www.iprbookshop.ru/autologin).

This is not necessarily a bad thing as this is a service that you want to use (since you installed this plugin) - just maybe we should somehow require that this kind of information is exposed in plugin description (what user's data is sent and where)?


Tomek

Average of ratings: -
In reply to Tomasz Muras

Re: GDPR, privacy and plugins sending the information to external entities

by David Mudrák -
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What we do not have covered, in terms of managing user's data is the situation where a plugin sends data externally.

That's not 100% correct. The privacy API does cover this case: https://docs.moodle.org/dev/Privacy_API#Indicating_that_you_export_data_to_an_external_location

Plugins that share info with an external system (like the one you mention) are expected to declare that via the privacy API so that admins can act accordingly. If a plugin does not have this implemented correctly, it is considered as a standard bug that should be reported and fixed.

Additionally to this, there is a dedicated field in the plugin record called "Potential privacy issues" where the maintainers should provide more information and/or highlight all these things.

Average of ratings: Useful (4)