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--- shared:privacy_setup [2021/12/13 07:48] – [Privacy and Cookie policies] ggmei
+++ shared:privacy_setup [2022/03/08 18:50] (current) – ggmei
@@ Line 1: / Line 1: @@
-====== Privacy Setup ======
+====== Privacy Setup (DRAFT) ======
 The scope of the [[https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en|European GDPR law]], and of the other data protection laws for other countries, is wide and affects how the company processes all kinds of personal data.
-Some of this processing happens on the website, which has to be compliant with the law. Three elements are needed:
+Some of this processing happens on the website, which has to be compliant with the law. Three elements are strictly needed:
   - The design of the website must be compliant
-  - [[#privacy_and_cookie_policies|Privacy & Cookie policies]] have to be provided
+  - [[#privacy_and_cookie_policies|Privacy & Cookie policies]], either provided by the company or via Cone
-  - [[#cookie_consent|Cookie consent]] has to be obtained by the users before placing any cookie
+  - [[#cookie_consent|Cookie consent]] and block/unblock cookies, usually but not necessarily provided by Cone
-There are also two further elements, that are less clear about the practical implementation and need:
+There are also two further elements that may be activated on company's requests:
   * [[#cookie_preference_log|Cookie preference log]]
   * [[#record_of_consents|Record of consents]]
@@ Line 37: / Line 37: @@
 **Cost**: extra on the annual fee, which includes Cone and third-party's fees. It's a flat fee that doesn't depend on the number of languages.
-** Cookie consent solution **
+Iubenda's Cookie consent solution:
   * [it] https://www.iubenda.com/it/help/680-introduzione-cookie-solution
   * [en] https://www.iubenda.com/en/help/1177-cookie-solution-getting-started
@@ Line 45: / Line 45: @@
 Registro Preferenze Cookie
+https://cookie-script.com/record-visitor-consents.html
 ==== Record of consents ====
+It is also a broad requirement to keep a record of all the given consents. How this applies to the website processing in general is less clear.
+One approach is to keep a record of a case by case processing, such as:
+  * keep a screenshot of the information and registration forms
+  * keep a list of registration and information requests with date and IP
+  * see case by case for every other service used (newsletters, CRM etc.)
+There are on the market also systems to cover this organically (see for example [[https://www.iubenda.com/en/help/6469-consent-solution-getting-started|Iubenda Consent solution]]) which also need to be integrated manually with every processing source.
+**Cost**: extra on the annual fee
+==== GDPR references ====
+  * Iubenda on GDPR and other privacy laws [it] https://www.iubenda.com/it/help/5424-guida-gdpr
+  * Frequent cases (blog, ecommerce, newsletter) [it] https://www.iubenda.com/it/help/9113-blog-gdpr-come-adeguarsi
-https://www.iubenda.com/en/help/6469-consent-solution-getting-started