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• How should I write my privacy notice for Matomo Analytics under GDPR ?

  24 avril 2018, par InnoCraft

  Important note : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to show you an example of a privacy notice for Matomo under GDPR. This work comes from our interpretation of the UK privacy commission : ICO. It cannot be considered as professional legal advice. So as GDPR, this information is subject to change. We strongly advise you to have a look at the different privacy authorities in order to have up to date information.

  A basic rule of thumb is that if you are not processing personal data, then you do not need to show any privacy notice. But if you are doing so, such as processing full IP addresses, then a privacy notice is required at the time of the data collection. Please note that personal data may also be hidden, for example, in page titles or page URLs.

  In this blog post, we will define what a privacy notice is according to GDPR and how to write it if you are using Matomo and you are processing personal data.

  What is a privacy notice under GDPR ?

  One of the most important rights that a data subject has under GDPR, is the right to be informed about the collection and use of their personal data.

  Here is what ICO is saying about the privacy notice :

  “You must provide individuals with information including : your purposes for processing their personal data, your retention periods for that personal data, and who it will be shared with. We call this ‘privacy information’.”

  “When you collect personal data from the individual it relates to, you must provide them with privacy information at the time you obtain their data.”

  Note that a privacy notice is different from a privacy policy.

  The privacy notice has to include :

  • the reasons why you are processing the personal data
  • for how long
  • who the different parties you are going to share them with are

  So whatever lawful basis you are using (explicit consent or legitimate interest), you need to have a privacy notice if you collect personal data.

  What does this privacy notice look like ?

  ICO is providing best practices in order to display the information :

  • a layered approach
  • dashboards
  • just-in-time notices
  • icons
  • mobile and smart device functionalities

  Once more, it really depends on the data you are processing with Matomo. If you wish to track personal data on the entire website, you will probably have an upper or footer privacy notice such as :

  

  If you wish to process specific data, you could also insert just-in-time notices such as :

  

  What is the information you need to disclose to the final user ?

  To us, there are two things to distinguish between the privacy notice and the privacy policy.

  According to ICO, the privacy notice needs to include the 3 following elements :

  • the reasons why you are processing the personal data
  • for how long
  • who are the different parties you are going to share them with

  But you also need to inform them about :

  • The name and contact details of your organisation.
  • The name and contact details of your representative (if applicable).
  • The contact details of your data protection officer (if applicable).
  • The purposes of the processing.
  • The lawful basis for the processing.
  • The legitimate interests for the processing (if applicable).
  • The categories of personal data obtained (if the personal data is not obtained from the individual it relates to).
  • The recipients or categories of recipients of the personal data.
  • The details of transfers of the personal data to any third countries or international organisations (if applicable).
  • The retention periods for the personal data.
  • The rights available to individuals in respect of the processing.
  • The right to withdraw consent (if applicable).
  • The right to lodge a complaint with a supervisory authority.
  • The source of the personal data (if the personal data is not obtained from the individual it relates to).
  • The details of whether individuals are under a statutory or contractual obligation to provide the personal data (if applicable, and if the personal data is collected from the individual it relates to).
  • The details of the existence of automated decision-making, including profiling (if applicable).

  Pretty long, don’t you think ? In order to reduce it, you can either adopt a layered approach where your “pop-up” window will act as a drop down menu. Or from what we understood, page 5 of this document provided by ICO, a privacy notice can link to a more detailed document, such as a privacy policy page.

  Examples

  Let’s take the example of a website which tracks the non-anonymised full IP address, and using User ID functionality to keep track of logged-in users. Under GDPR, the owner of the website will have to choose either to process personal data based on “Legitimate interests” or on “Consent”. Here is how it will look like :

  Example of a privacy notice under GDPR Legitimate interests

  This site uses Matomo to analyze traffic and help us to improve your user experience.

  We process your email address and IP address and cookies are stored on your browser for 13 months. This data is only processed by us and our web hosting platform. Please read our Privacy Policy to learn more.

  Example of a privacy notice under GDPR Consent

  This site uses Matomo to analyze traffic and help us to improve your user experience.

  We process your email address and IP address and cookies are stored on your browser for 13 months. This data is only processed by us and our web hosting platform.

  [Accept] or [Opt-out]

  Please read our Privacy Policy to learn more.

  Once that information is provided to the user, you can then link it to your privacy policy where you will provide more details about it. Soon we will issue a blog post dealing with how to write a privacy policy page for Matomo.

  The post How should I write my privacy notice for Matomo Analytics under GDPR ? appeared first on Analytics Platform - Matomo.

• Help us Reset The Net today on June 5th

  5 juin 2014, par Piwik Core Team — Community, Meta

  This blog post explains why the Piwik project is joining ResetTheNet online protest and how you can help make a difference against mass surveillance. It also includes an infographic and links to useful resources which may be of interest to you.

  Snowden revelations, a year ago today

  On June 5, 2013 the Guardian newspaper published the first of Edward Snowden’s astounding revelations. It was the first of a continuous stream of stories that pointed out what we’ve suspected for a long time : that the world’s digital communications are being continuously spied upon by nation states with precious little oversight.

  Unfortunately, mass surveillance is affecting the internet heavily. The Internet is a powerful force that can promote democracy, innovation, and creativity, but it’s being subverted as a tool for government spying. That is why Piwik has decided to join Reset The Net.

  June 5, 2014 marks a new year : a year that will not just be about listening to the inside story of mass surveillance, but a new year of fighting back !

  How do I protect myself and others ?

  Reset the Net is asking everyone to help by installing free software tools that are designed to protect your privacy on a computer or a mobile device.

  Reset the Net is also calling on websites and developers to add surveillance resistant features such as HTTPS and forward secrecy.

  Participate in ResetTheNet online protest

  Have you got your own website, blog or tumblr ? Maybe you can show the Internet Defense League’s “Cat Signal !” on your website.Get the code now to run the Reset the Net splash screen or banner to help make privacy viral on June 5th.

  Message from Edward Snowden

  Evan from FFTF sent us this message from Edward Snowden and we thought we would share it with you :

  One year ago, we learned that the internet is under surveillance, and our activities are being monitored to create permanent records of our private lives — no matter how innocent or ordinary those lives might be.

  Today, we can begin the work of effectively shutting down the collection of our online communications, even if the US Congress fails to do the same. That’s why I’m asking you to join me on June 5th for Reset the Net, when people and companies all over the world will come together to implement the technological solutions that can put an end to the mass surveillance programs of any government. This is the beginning of a moment where we the people begin to protect our universal human rights with the laws of nature rather than the laws of nations.

  We have the technology, and adopting encryption is the first effective step that everyone can take to end mass surveillance. That’s why I am excited for Reset the Net — it will mark the moment when we turn political expression into practical action, and protect ourselves on a large scale.

  Join us on June 5th, and don’t ask for your privacy. Take it back.

  – Message by Edward Snowden

  ResetTheNet privacy pack infographic

  

  Additional Resources

  Configure Piwik for Security and Privacy

  • Turn on automatic SSL redirection in your Piwik.
  • Configure Piwik for advanced Privacy.
  • Best security practises for Piwik.

  More info

  • Learn why this matters (EFF)
  • Data Privacy Day – Why is privacy important ? (Piwik)
  • Web Analytics Privacy (Piwik)

• Help us Reset The Net today on June 5th

  5 juin 2014, par Piwik Core Team — Community, Meta

  This blog post explains why the Piwik project is joining ResetTheNet online protest and how you can help make a difference against mass surveillance. It also includes an infographic and links to useful resources which may be of interest to you.

  Snowden revelations, a year ago today

  On June 5, 2013 the Guardian newspaper published the first of Edward Snowden’s astounding revelations. It was the first of a continuous stream of stories that pointed out what we’ve suspected for a long time : that the world’s digital communications are being continuously spied upon by nation states with precious little oversight.

  Unfortunately, mass surveillance is affecting the internet heavily. The Internet is a powerful force that can promote democracy, innovation, and creativity, but it’s being subverted as a tool for government spying. That is why Piwik has decided to join Reset The Net.

  June 5, 2014 marks a new year : a year that will not just be about listening to the inside story of mass surveillance, but a new year of fighting back !

  How do I protect myself and others ?

  Reset the Net is asking everyone to help by installing free software tools that are designed to protect your privacy on a computer or a mobile device.

  Reset the Net is also calling on websites and developers to add surveillance resistant features such as HTTPS and forward secrecy.

  Participate in ResetTheNet online protest

  Have you got your own website, blog or tumblr ? Maybe you can show the Internet Defense League’s “Cat Signal !” on your website.Get the code now to run the Reset the Net splash screen or banner to help make privacy viral on June 5th.

  Message from Edward Snowden

  Evan from FFTF sent us this message from Edward Snowden and we thought we would share it with you :

  One year ago, we learned that the internet is under surveillance, and our activities are being monitored to create permanent records of our private lives — no matter how innocent or ordinary those lives might be.

  Today, we can begin the work of effectively shutting down the collection of our online communications, even if the US Congress fails to do the same. That’s why I’m asking you to join me on June 5th for Reset the Net, when people and companies all over the world will come together to implement the technological solutions that can put an end to the mass surveillance programs of any government. This is the beginning of a moment where we the people begin to protect our universal human rights with the laws of nature rather than the laws of nations.

  We have the technology, and adopting encryption is the first effective step that everyone can take to end mass surveillance. That’s why I am excited for Reset the Net — it will mark the moment when we turn political expression into practical action, and protect ourselves on a large scale.

  Join us on June 5th, and don’t ask for your privacy. Take it back.

  – Message by Edward Snowden

  ResetTheNet privacy pack infographic

  

  Additional Resources

  Configure Piwik for Security and Privacy

  • Turn on automatic SSL redirection in your Piwik.
  • Configure Piwik for advanced Privacy.
  • Best security practises for Piwik.

  More info

  • Learn why this matters (EFF)
  • Data Privacy Day – Why is privacy important ? (Piwik)
  • Web Analytics Privacy (Piwik)