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GDPR Discussion 5 years 10 months ago #68600

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We only recently became aware of the European Union GDPR data protection / privacy requirements and the looming May 25th compliance deadline. Discussions are underway how best to address this in an effective manner. Because we are volunteers maintaining and updating this system, there are practical limits on how fast we can respond to these sorts of things. (But this is on our "radar screen".)

References we have reviewed:
ico.org.uk/media/1624219/preparing-for-the-gdpr-12-steps.pdf
Semantic GDPR Reference
www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/default.aspx
assessment.microsoft.com/gdpr-compliance

In the meantime, I wanted to start this thread to inform our users of the state of data privacy and security as it currently stands with FreeToastHost.

Some of the following posts I have put in this thread could be turned into a help doc or some other more permanent documentation. However, at this point, I just wanted to get some information out to facilitate appropriate discussion.

As we are learning about this new data privacy requirement as quickly as we can, we would greatly welcome insights and input from any of our users who are familiar with the new requirements. If you have suggestions about how to ensure that FreeToastHost is GPDR compliant, please feel free to offer those as well. Many of our best insights, ideas, and input come from our users.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
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GDPR Discussion 5 years 10 months ago #68601

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1. Personal Information that we hold:
In general, FreeToastHost is designed to work with a person's name and an email address, at a minimum. Email addresses may be deleted, but this will degrade the benefits of the system to that user.

Users may optionally have phone numbers and/or Toastmasters member number entered, but that is not required. The system does store passwords in encrypted form. Names, email addresses, phone numbers, and TI member numbers are not currently stored in encrypted form in the FTH database.

At this time, we do not offer a feature for using a pseudonym / username instead of your real name (it could be added). However, there is no check for the validity of a person's real name entered in the system, so "Bugs Bunny" or other could be entered instead of a real name. (as an example)

At this time, we do not have a way to forget a user other than deleting them from the system.

In general, all information and content in the system comes from one of 4 sources:
1. User provided information or content (including your contact information)
2. Publicly available information or content provided by Toastmasters International
3. Publicly available open source information or content found on the Internet and vetted by us.
4. Information that the system has generated (calculated) and stored for later retrieval.

The system does not share information with other systems or organizations--it is not designed that way.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68602

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2. How we use your personal information:

The system uses actual names to make it easier for club members to identify who is being referenced. The system does not use phone numbers for its own operations--phone numbers are only entered and stored for the benefit of members to communicate via phone.

Email addresses are used for email communications between members, with non-members, for distributing system generated content, and for system notifications.

Email security is in place and in use by the system: DKIM Signatures, SPF Records, and DMARC are all deployed and in use for email security. SpamAssassin is in use for SPAM protection. Club/district specific email black lists (for blocking email from senders) can also be created by each club/district.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68603

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3. Retention of deleted data

The system is designed to retain deleted custom web page content, deleted member/non-member information, and deleted agenda information for no longer than 30 days "with regular use". (This retention is to allow for undeleting accidentally deleted information.) "With regular use" means that if no one accessed the data for 45 days, for example, the deleted data would actually be purged once that access happens. The system purges deleted data as the data is accessed--there is no "nightly purge function" that is getting rid of deleted data. This is by design.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie
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GDPR Discussion 5 years 10 months ago #68604

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4. Exporting of personal information.

Personal information can be exported from the Membership Management module, but not currently from the Member Profile.

The exported information is in a CSV format, which should be fairly portable.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68605

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5. Encryption

Passwords are stored in encrypted form in our database. Names, email addresses, and phone numbers are not stored in encrypted form at this time.

File transfers to / from the server are only encrypted if your website is using HTTPS. Therefore, I would recommend that you enforce that to be on for everyone that uses your website.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, herman.koester
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GDPR Discussion 5 years 10 months ago #68606

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6. Adding personal information to the website.

At this time, we lack a double opt-in approach to adding people's personal information to the website.

Ideally, if someone's contact information is added in Membership Management, it would be kept in a deactivated state until the person clicks a confirmation link in a confirmation email sent to them by the system. That does not currently happen.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, herman.koester, NSB, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68607

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7. Retention of non-member contact information.

Currently, there is no limit on how long non-member contact information is retained by clubs, unless they click the Unsubscribe link in an email sent to them. Even if they unsubscribe, only their email address is wiped out--their name and other information is still in the system. This is problematic, and will need to be addressed soon.

In this case, the non-member has no way to get themselves removed unless they receive an email with an Unsubscribe link or if they contact the club to get themselves removed. (which they may not want to do)

EDIT: As of 5/13/2018, we are now completely deleting information for people that click the Unsubscribe link. Also, there will not be any kind of undelete possible for this.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, herman.koester, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68608

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8. Informed Consent Statements

At this time, we do not use any Informed Consent Statements triggered by the website operations. We do have a Terms of Use Statement, but that is not strictly focused on data privacy and is only available via the help documents on this support website.

EDIT: As of 5/13/2018, there is now a cookie pop-up that is linked to a new draft FreeToastHost Privacy and Cookie Policy.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68609

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9. Information stored on your computer

While the system does store information in cookie files and local storage on your computer, the only data that would contain personal information is an optional email signature that you can set up. (Assuming that you put your name in it.) It is not required for proper system operation.

EDIT: As of 5/12/2018, two cookies have been eliminated from use... less stuff stored on your computer.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie
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GDPR Discussion 5 years 10 months ago #68610

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10. Archive Email Account

If you use an archive email account that you have configured your FreeToastHost to copy emails to, you should be aware that it could have personal information in those archived emails. You should either set up a rule to clear out old emails periodically from that account or choose not to use the archive account with your FreeToastHost website.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie, lynn648.tm@gmail.com
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GDPR Discussion 5 years 10 months ago #68626

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bump
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: laurafa, fatthumbs
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GDPR Discussion 5 years 10 months ago #68701

  • LindaMann
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I have all of the members, former members and guests addresses, phone numbers and emails in my club sections for officers only. Is that safe or will it be when this is effected?
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GDPR Discussion 5 years 10 months ago #68706

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Linda, the official GDPR compliance deadline is May 25th. I am not sure we will get all the required changes made by then.

We have gotten an official communication from Toastmasters that they want FreeToastHost to be GDPR compliant. This is not something we are just making up on whim... It is a very real challenge to how the system is designed to work and we are grappling with it.

However, some things this will absolutely impact is whether or not you can add anyone's contact information to your website (will be by permission only) and the regulations will also affect how long you can hold onto someone's contact information.

There are other things, as well...

However, this will affect all clubs and districts using FTH... we do not have the resources to produce a compliant version and non-compliant version of the system (for use outside the EU). Even if we did that, it would be problematic because of the clubs using the system all over the world.

Because of this, we have to make the entire system compliant... and bear the brunt of our users likely complaints as a result. :(
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie
Last edit: by SteveTheTechie.
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GDPR Discussion 5 years 10 months ago #68735

  • Toniaclue
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Steve,

How do you "enforce having HTTPS on for the website?"

Thanks,

Tonia
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GDPR Discussion 5 years 10 months ago #68737

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Tonia,

There is currently a setting for that in the Basic Settings tab of the admin console.

However, this setting is very likely to go away (or at least the ability to not use https) and everyone will be forced to use https... if someone tries to load a website with http: instead of https: they would be redirected to the website w/ https: instead.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Toniaclue, lynn648.tm@gmail.com, nalmasy
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GDPR Discussion 5 years 10 months ago #68739

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Thanks, Steve. I just turned it on for our club website.
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GDPR Discussion 5 years 10 months ago #68786

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I saw the message. The all caps did work for getting attention.

I am a super user for my district. I have read the information on this thread, but the main question that has not been answered is "what do I need to do for my club?" "What do I need to tell the current administrator for the district website that they need to do for the district?" "How will this impact our current operations?"

When adding a new member, I simply use firstname lastname This email address is being protected from spambots. You need JavaScript enabled to view it.
Some club officers have had phone numbers added in the past for the contact us page.

Omaha Toastmasters Club 281
281.toastmastersclubs.org/

District 24 Toastmasters
d24tm.org/


[2018-05-08 06:58:05 GMT, FTH Support / Developer] *EVERY CLUB AND DISTRICT* THAT USES FREETOASTHOST NEEDS TO GET INTERESTED IN THE UPCOMING GDPR DATA PRIVACY REGULATIONS AND START ASKING QUESTIONS ABOUT IT IN THE FTH SUPPORT FORUMS. VERY IMPORTANT!

Hopefully, using caps got your attention. I do not normally do all caps (obnoxious), but it is really important that every club and district that uses FreeToastHost start asking questions about these regulations and their impact and get up to speed on them.

Some changes will be coming to FreeToastHost *soon* related to these regulations that many clubs and districts are going to be blindsided by and really not like very much. (But we *have* to do these changes to be in compliance... very sorry about that.)

*** Please take this seriously and ask questions ... we are doing that also.

More details: support.toastmastersclubs.org/2011-10-23...0558-gdpr-discussion

Regards,

Steve James, DTM
FreeToastHost Developer
support.toastmastersclubs.org
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GDPR Discussion 5 years 10 months ago #68796

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Some specific impacts to expect:

1. Clubs need to be very careful about how people's personal information is used. While this is currently an EU regulation, we expect to see some version of this in the US in the future. (it is only a matter of time)

Specifics related to FTH and websites:

1. DO force HTTPS to be used.
2. DO NOT use any member's name, email address, or phone number on any web pages without written permission or at least some sort of opt-in mechanism that will document them ok'ing that. In general, it is just not a good idea... if that member leaves the club, then someone would have to remember to remove them... It is just problematic.
3. Cookies or other potential tracking mechanisms have to be agreed to... We will handle that for FTH... I am working on that. If not agreed to, they will not be able to log in. ("Visitor" version of website only.)
IMPLEMENTED 5/13/2018
4. Members have to give permission for their contact information to be added and used in the website. Again, we will handle that. Members must be able to easily remove themselves from the website.
5. Non-members must give permission for their contact information to be added/retained in the website.
6. You need to remove any references to former members and other non-members from your web-pages unless you have written permission to continue to use their info.
7. Get disciplined about using photo release forms for member photos used on your web pages. Get disciplined about removing old photos that have former members in them.

This is a starting list... there will be other things, also.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
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GDPR Discussion 5 years 10 months ago #68802

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Thank you, Steve - you are so clear with this info.

Wondering if Toastmasters will be updating the guest/visitor and the membership forms to include an opt-in or opt-out for use of name, email, etc. Hopeful...

Thanks again to our savvy FTH support team members. You folks are the best!
THANK YOU!
- Nancy -
CLUB: 5736
WEBSITE: verbalexp.toastmastersclubs.org/
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GDPR Discussion 5 years 10 months ago #68804

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NSB: Bryan has obtained a copy of the forms that WHQ legal is emailing to the EU clubs. (Only for EU clubs.)

We have seen those...
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: NSB
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GDPR Discussion 5 years 10 months ago #68816

  • TomColling
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As you can see from 281.toastmastersclubs.org/ we have found that photos on our home page and Facebook help promote our club and demonstrate that we are warm, welcoming and diverse.

We have done our best to comply with the photo release, but to be honest it can be an administrative burden.

Is there any way to build in the photo release into the member profile? This would allow the member to say yes or no, but then the record keeping is in a safe space (your database) instead of something subject to being lost between the transfer of leadership roles each year. The agenda speech title database has been a true blessing over the years for this reason, especially with members losing manuals.

Tom Colling

Omaha Toastmasters Club 281
281.toastmastersclubs.org/

District 24 Toastmasters
d24tm.org/

Some specific impacts to expect:

7. Get disciplined about using photo release forms for member photos used on your web pages. Get disciplined about removing old photos that have former members in them.

This is a starting list... there will be other things, also.

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GDPR Discussion 5 years 10 months ago #68818

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The photo release is not specifically part of the upcoming regulations. However, as a general good practice in the same sort of thinking, having a photo release is always a good idea.

Also, having it in the profile is not sufficient since group photos may be kept in a website after a member leaves a club.
Regards,

Steve James, DTM
FreeToastHost System Developer
Officer Emeritus, Mindful Communicators (Club 1966, District 52) A President's Distinguished Club for each of the last 10 years.

>>> Please put your club number in your forum profile. CLICK here to edit your profile.
The following user(s) said Thank You: Roxie
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GDPR Discussion 5 years 10 months ago #68819

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Ti is recommending ALL releases be kept in a lock box accessed by Secretary and President only.

Thank you,

Brian McDonald DTM, PDD D61
FTH Lead Technical Support
member Cataraqui Valley Toastmaster 9560
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GDPR Discussion 5 years 10 months ago #68831

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I believe our site is .. I turned it to https .. but turned it off as I feared it would cause me to have to rebuild things. How have you found the flip? I'm rusty as it has been a few years since I really dived into editing the site back when it was new. Is it usually just minor things that are easily found?

When we do the flip .. I will just keep you close at hand so that our website remains usable for the most part.
Glenn Laycock, Website Administrator
Club 2170, Venio Dictum Toastmasters Club
www.toastmasters.mb.ca
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