From 4274cb5d2142c0f5951670cd9c5d692ad21c53d6 Mon Sep 17 00:00:00 2001
From: Benjamin Bellamy <ben@podlibre.org>
Date: Fri, 1 Apr 2022 13:42:17 +0000
Subject: [PATCH] docs(gdpr.txt): add purpose block for analytics data
---
GDPR.txt | 23 +++++++++++++++++++++++
public/.well-known/GDPR.yml | 24 ++++++++++++++++++++++++
2 files changed, 47 insertions(+)
diff --git a/GDPR.txt b/GDPR.txt
index 9cce01c3d5..f8f7f13c83 100644
--- a/GDPR.txt
+++ b/GDPR.txt
@@ -6,6 +6,29 @@
# in particular. As a hosting provider, you must inform your users of their
# rights and how their data are used and protected.
+purpose:
+ Deduplicate number of audio file downloads made by the same listener
+ for analytics purposes
+lawfulness: legitimate interest
+
+data: (User IP address + Browser User Agent)
+required: yes
+visibility: none
+description:
+ In order to produce analytics data comparable to the podcasting
+ ecosystem standards, the User IP address (REMOTE_ADDR) with the
+ browser User Agent (HTTP_USER_AGENT) are stored when an audio file
+ is downloaded.
+mitigation:
+ The data (User IP address + Browser User Agent) is never stored in plain
+ format.
+ The data is concatenated with a cryptographic salt, the current date,
+ and the podcast or episode IDs.
+ The data is hashed (using sha1) after being concatenated and before
+ being stored.
+ The data is stored in a cache database (eg. Redis).
+ The data expires every day at midnight (server time).
+
purpose: Connect users to their accounts
lawfulness: legitimate interest
diff --git a/public/.well-known/GDPR.yml b/public/.well-known/GDPR.yml
index 8ef0206382..40c822bafb 100644
--- a/public/.well-known/GDPR.yml
+++ b/public/.well-known/GDPR.yml
@@ -7,6 +7,30 @@
# rights and how their data are used and protected.
purposes:
+ - description: |
+ Deduplicate number of audio file downloads made by the same listener for
+ analytics purposes
+ lawfulness: legitimate interest
+ data:
+ - field: (User IP address + Browser User Agent)
+ required: yes
+ visibility: none
+ description: |
+ In order to produce analytics data comparable to the podcasting
+ ecosystem standards, the User IP address (REMOTE_ADDR) with the
+ browser User Agent (HTTP_USER_AGENT) are stored when an audio file
+ is downloaded.
+ mitigation: |
+ The data (User IP address + Browser User Agent) is never stored in
+ plain format.
+ The data is concatenated with a cryptographic salt, the current date,
+ and the podcast or episode IDs.
+ The data is hashed (using sha1) after being concatenated and before
+ being stored.
+ The data is stored in a cache database (eg. Redis).
+ The data expires every day at midnight (server time).
+ retention: 24 hours maximum
+
- description: Connect users to their accounts
lawfulness: legitimate interest
data:
--
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