GDPR compliance

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  1. GDPR Compliance for Wiki Administrators and Users

This article provides a comprehensive overview of the General Data Protection Regulation (GDPR) and its implications for MediaWiki installations, aimed at both administrators and users. It details the requirements, practical steps for compliance, and ongoing considerations. Understanding GDPR is crucial for maintaining a legally compliant and trustworthy wiki.

What is GDPR?

The General Data Protection Regulation (GDPR) is a regulation in EU law on data protection and privacy when individuals within the European Economic Area (EEA) are involved. It came into effect on May 25, 2018, and applies to all organizations processing the personal data of people in the EEA, regardless of the organization's location. "Personal data" is broadly defined and includes any information relating to an identified or identifiable natural person ("data subject"). This includes not only names and email addresses but also IP addresses, location data, and online identifiers.

The GDPR aims to give individuals more control over their personal data and to simplify the regulatory environment for international business. It's not simply a European issue; any wiki accessible to users within the EEA must comply, even if the server is located elsewhere. Failure to comply can result in significant fines – up to €20 million or 4% of annual global turnover, whichever is higher.

Key GDPR Principles

Several core principles underpin the GDPR. Understanding these is fundamental to achieving compliance:

  • **Lawfulness, Fairness, and Transparency:** Data processing must have a legal basis (e.g., consent, contract, legitimate interests). Information about data processing must be provided to users in a clear and understandable way. This is often achieved through a Privacy Policy.
  • **Purpose Limitation:** Data can only be collected for specified, explicit, and legitimate purposes.
  • **Data Minimization:** Only data necessary for the purpose should be collected and processed. Avoid collecting information "just in case."
  • **Accuracy:** Data must be accurate and kept up to date. Mechanisms should be in place to rectify inaccurate data.
  • **Storage Limitation:** Data should be kept only as long as necessary for the purpose. Data retention policies are essential.
  • **Integrity and Confidentiality (Security):** Data must be processed securely to prevent unauthorized access, loss, or damage. This is a major concern for wiki administrators. See Security best practices for details.
  • **Accountability:** The data controller (often the wiki administrator) is responsible for demonstrating compliance with the GDPR.

How GDPR Applies to MediaWiki

MediaWiki, by its nature, processes personal data. Here's a breakdown of how GDPR applies to common wiki features:

  • **User Accounts:** The creation of user accounts inherently involves processing personal data (username, email address).
  • **IP Addresses:** IP addresses are logged by default in MediaWiki's server logs. These are considered personal data.
  • **Edit History:** Edit history, while generally public, can potentially reveal information about users.
  • **Cookies:** MediaWiki uses cookies for various purposes (session management, user preferences).
  • **Forms:** If your wiki uses forms (e.g., contact forms, report forms), these collect personal data.
  • **Special Pages:** Special pages like User contributions and Whois reveal user data.
  • **Watchlists:** Watchlists track user interests and potentially reveal preferences.
  • **Email Communication:** Sending emails through the wiki (e.g., notifications) processes email addresses.
  • **External Services:** Integration with external services (e.g., OAuth login) introduces additional data processing considerations.

Steps to Achieve GDPR Compliance in MediaWiki

Achieving GDPR compliance is an ongoing process, not a one-time fix. Here's a structured approach:

1. Data Audit:

  • Identify all personal data processed by your MediaWiki installation.
  • Document the purpose of processing each type of data.
  • Determine the legal basis for processing (e.g., consent, legitimate interest).
  • Map the data flow – where does the data come from, where is it stored, who has access?

2. Privacy Policy: 

   *   What personal data is collected.
   *   The purpose of collecting the data.
   *   The legal basis for processing.
   *   How long the data is retained.
   *   Users' rights (see section below).
   *   Contact information for data protection inquiries.
  • Make the Privacy Policy easily accessible – link it in the footer of every page.

3. Consent Management (If Applicable):

  • If you rely on consent as the legal basis for processing data (e.g., for optional cookies), you must obtain explicit, informed, and freely given consent.
  • Implement a consent mechanism (e.g., a cookie banner) that allows users to opt-in or opt-out. Consider using extensions like Consent, or integrating with a Consent Management Platform (CMP).
  • Keep records of consent.

4. Data Subject Rights:

The GDPR grants individuals several rights regarding their personal data. You must have processes in place to handle these requests:

  • **Right to Access:** Users can request a copy of their personal data. MediaWiki doesn't have a built-in feature for this; you may need to develop a custom script or use an extension.
  • **Right to Rectification:** Users can request to correct inaccurate or incomplete data. Provide a mechanism for users to update their profile information.
  • **Right to Erasure ("Right to be Forgotten"):** Users can request to have their personal data deleted. Implement a process to securely delete user accounts and associated data. Use Deletion Policy to explain the process.
  • **Right to Restriction of Processing:** Users can request to limit how their data is processed.
  • **Right to Data Portability:** Users can request to receive their data in a portable format.
  • **Right to Object:** Users can object to the processing of their data in certain circumstances.

5. Data Security:

  • **Secure your MediaWiki installation:**
   *   Keep MediaWiki and all extensions up to date.
   *   Use a strong password for the database and wiki administrator account.
   *   Implement HTTPS encryption (SSL/TLS).
   *   Regularly back up your wiki. See Backup and restore.
   *   Restrict access to sensitive files and directories.
   *   Implement a web application firewall (WAF).
  • **Protect against data breaches:**
   *   Develop a data breach response plan.
   *   Report data breaches to the relevant authorities within 72 hours.
  • **Anonymization and Pseudonymization:** Consider anonymizing or pseudonymizing data where possible.

6. Data Retention:

  • Establish a data retention policy that specifies how long different types of data are stored.
  • Delete data when it's no longer needed for the purpose it was collected.
  • Consider archiving older data instead of deleting it.

7. Server Logs:

  • Review your server log configuration. Minimize the amount of personal data logged (e.g., IP addresses).
  • Consider anonymizing IP addresses in logs.
  • Implement log rotation and retention policies.

8. Cookies:

  • Identify all cookies used by your MediaWiki installation.
  • Categorize cookies (e.g., essential, functional, analytics, advertising).
  • Obtain consent for non-essential cookies (using a cookie banner).
  • Provide users with information about cookies and how to manage them.

9. Third-Party Services:

  • If you use third-party services (e.g., analytics, advertising, OAuth login), ensure they are GDPR compliant.
  • Review their privacy policies and data processing agreements.
  • Consider using privacy-focused alternatives.

10. Documentation and Accountability:

  • Document all your GDPR compliance efforts.
  • Maintain records of data processing activities.
  • Regularly review and update your policies and procedures.
  • Assign responsibility for GDPR compliance to a specific individual or team.

Useful Extensions

Several MediaWiki extensions can assist with GDPR compliance:

  • **Consent:** Manages cookie consent. [1]
  • **PrivacyLink:** Adds a link to your privacy policy in the footer. [2]
  • **UserMerge:** Facilitates merging user accounts, which can be helpful for handling data rectification requests. [3]
  • **DeleteUser:** Simplifies the process of deleting user accounts and associated data. [4]
  • **ConfirmEdit:** Reduces spam and vandalism, potentially reducing the amount of personal data collected in edit histories. [5]

Ongoing Considerations

GDPR compliance is not a one-time event. You need to stay informed about changes in the law and best practices:

  • **Regular Audits:** Conduct regular data audits to ensure your wiki remains compliant.
  • **Training:** Provide training to administrators and users on GDPR principles.
  • **Stay Updated:** Monitor changes to GDPR guidance and case law.
  • **Data Protection Impact Assessments (DPIAs):** Conduct DPIAs for high-risk processing activities.
  • **Review Third-Party Services:** Regularly review the GDPR compliance of third-party services.

Resources and Further Information

Privacy Policy Data retention policies Security best practices User rights Consent management Deletion Policy Backup and restore User contributions Whois Data audit

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