June 2, 2018

워드프레스에 GDPR 적용하기

워드프레스에 GDPR 적용하기...

GDPR은 EU에서 2018.5.26일부터 적용되는 개인정보 보호에 관한 새로운 규정이라고 한다. 모든 웹사이트/온라인 쇼핑몰등은 유럽 사용자를 위해 개인정보에 대한 안내를 해야 한다는 거다.

워드프레스 Setting > Privacy로 가서 아래를 참조하여 새로운 Privacy 페이지를 새로 만들거나, 아니면 기존의 개인정보 처리방침에 대한 안내 페이지가 있다면 그것을 수정하면 된다. 아래의 내용 또는 GDPR를 숙지한 후 개인정보취급 정보 란에 GFPR의 요구사항을 명시하면 될 것 같다.

아래는 워드프레스에서 설명하고 있는 GDPR 관련 가이드이니 이를 참조하면 좋을 듯 싶다.

GDPR 알아보기

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Introduction

Hello,
This text template will help you to create your web site’s privacy policy.

We have suggested the sections you will need. Under each section heading you will find a short summary of what information you should provide, which will help you to get started. Some sections include suggested policy content, others will have to be completed with information from your theme and plugins.

Please edit your privacy policy content, making sure to delete the summaries, and adding any information from your theme and plugins. Once you publish your policy page, remember to add it to your navigation menu.

It is your responsibility to write a comprehensive privacy policy, to make sure it reflects all national and international legal requirements on privacy, and to keep your policy current and accurate.

Source: WordPress
Who we are
In this section you should note your site URL, as well as the name of the company, organization, or individual behind it, and some accurate contact information.
The amount of information you may be required to show will vary depending on your local or national business regulations. You may, for example, be required to display a physical address, a registered address, or your company registration number.

Suggested text: Our website address is: https://www.ssobom.com.

What personal data we collect and why we collect it
In this section you should note what personal data you collect from users and site visitors. This may include personal data, such as name, email address, personal account preferences; transactional data, such as purchase information; and technical data, such as information about cookies.

You should also note any collection and retention of sensitive personal data, such as data concerning health.

In addition to listing what personal data you collect, you need to note why you collect it. These explanations must note either the legal basis for your data collection and retention or the active consent the user has given.

Personal data is not just created by a user’s interactions with your site. Personal data is also generated from technical processes such as contact forms, comments, cookies, analytics, and third party embeds.

By default WordPress does not collect any personal data about visitors, and only collects the data shown on the User Profile screen from registered users. However some of your plugins may collect personal data. You should add the relevant information below.
Comments

In this subsection you should note what information is captured through comments. We have noted the data which WordPress collects by default.
Suggested text: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media
In this subsection you should note what information may be disclosed by users who can upload media files. All uploaded files are usually publicly accessible.

Suggested text: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms
By default, WordPress does not include a contact form. If you use a contact form plugin, use this subsection to note what personal data is captured when someone submits a contact form, and how long you keep it. For example, you may note that you keep contact form submissions for a certain period for customer service purposes, but you do not use the information submitted through them for marketing purposes.

Cookies
In this subsection you should list the cookies your web site uses, including those set by your plugins, social media, and analytics. We have provided the cookies which WordPress installs by default.

Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites
Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Analytics
In this subsection you should note what analytics package you use, how users can opt out of analytics tracking, and a link to your analytics provider’s privacy policy, if any.

By default WordPress does not collect any analytics data. However, many web hosting accounts collect some anonymous analytics data. You may also have installed a WordPress plugin that provides analytics services. In that case, add information from that plugin here.
Who we share your data with

In this section you should name and list all third party providers with whom you share site data,
including partners, cloud-based services, payment processors, and third party service providers, and note what data you share with them and why. Link to their own privacy policies if possible.
By default WordPress does not share any personal data with anyone.

How long we retain your data
In this section you should explain how long you retain personal data collected or processed by the web site. While it is your responsibility to come up with the schedule of how long you keep each dataset for and why you keep it, that information does need to be listed here. For example, you may want to say that you keep contact form entries for six months, analytics records for a year, and customer purchase records for ten years.

Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data
In this section you should explain what rights your users have over their data and how they can invoke those rights.

Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data

In this section you should list all transfers of your site data outside the European Union and describe the means by which that data is safeguarded to European data protection standards. This could include your web hosting, cloud storage, or other third party services.

European data protection law requires data about European residents which is transferred outside the European Union to be safeguarded to the same standards as if the data was in Europe. So in addition to listing where data goes, you should describe how you ensure that these standards are met either by yourself or by your third party providers, whether that is through an agreement such as Privacy Shield, model clauses in your contracts, or binding corporate rules.

Suggested text: Visitor comments may be checked through an automated spam detection service.
Your contact information

In this section you should provide a contact method for privacy-specific concerns. If you are required to have a Data Protection Officer, list their name and full contact details here as well.
Additional information

If you use your site for commercial purposes and you engage in more complex collection or processing of personal data, you should note the following information in your privacy policy in addition to the information we have already discussed.

How we protect your data
In this section you should explain what measures you have taken to protect your users’ data. This could include technical measures such as encryption; security measures such as two factor authentication; and measures such as staff training in data protection. If you have carried out a Privacy Impact Assessment, you can mention it here too.

What data breach procedures we have in place
In this section you should explain what procedures you have in place to deal with data breaches, either potential or real, such as internal reporting systems, contact mechanisms, or bug bounties.

What third parties we receive data from
If your web site receives data about users from third parties, including advertisers, this information must be included within the section of your privacy policy dealing with third party data.

What automated decision making and/or profiling we do with user data
If your web site provides a service which includes automated decision making - for example, allowing customers to apply for credit, or aggregating their data into an advertising profile - you must note that this is taking place, and include information about how that information is used, what decisions are made with that aggregated data, and what rights users have over decisions made without human intervention.

Industry regulatory disclosure requirements
If you are a member of a regulated industry, or if you are subject to additional privacy laws, you may be required to disclose that information here.

CopyCopy suggested policy text from WordPress.

Source: WooCommerce
This sample language includes the basics around what personal data your store may be collecting, storing and sharing, as well as who may have access to that data. Depending on what settings are enabled and which additional plugins are used, the specific information shared by your store will vary. We recommend consulting with a lawyer when deciding what information to disclose on your privacy policy.

We collect information about you during the checkout process on our store.

What we collect and store
While you visit our site, we’ll track:
Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping

Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!

We’ll also use cookies to keep track of cart contents while you’re browsing our site.

Note: you may want to further detail your cookie policy, and link to that section from here.
When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:

Send you information about your account and order
Respond to your requests, including refunds and complaints
Process payments and prevent fraud

Set up your account for our store
Comply with any legal obligations we have, such as calculating taxes
Improve our store offerings

Send you marketing messages, if you choose to receive them
If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.

We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for XXX years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.
We will also store comments or reviews, if you choose to leave them.

Who on our team has access
Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:
Order information like what was purchased, when it was purchased and where it should be sent, and

Customer information like your name, email address, and billing and shipping information.
Our team members have access to this information to help fulfill orders, process refunds and support you.

What we share with others
In this section you should list who you’re sharing data with, and for what purpose. This could include, but may not be limited to, analytics, marketing, payment gateways, shipping providers, and third party embeds.

We share information with third parties who help us provide our orders and store services to you; for example --

Payments
In this subsection you should list which third party payment processors you’re using to take payments on your store since these may handle customer data. We’ve included PayPal as an example, but you should remove this if you’re not using PayPal.
We accept payments through PayPal. When processing payments, some of your data will be passed to PayPal, including information required to process or support the payment, such as the purchase total and billing information.
Please see the PayPal Privacy Policy for more details.

suggested policy text from WooCommerce.

Source: PayPal Express Checkout
By using this extension, you may be storing personal data or sharing data with an external service. Learn more about how this works, including what you may want to include in your privacy policy.

suggested policy text from PayPal Express Checkout.


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만약 기존에 Privacy 명시 페이지가 없다면.. 새로 만들기 버튼을 클릭하면 아래와 같은 양식으로 새로운 Privacy 페이지가 만들어진다. 이 양식에 언급해야할 사항을 명기하면 된다.

Who we are

Our website address is: https://www.ssobom.com.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

What data breach procedures we have in place

What third parties we receive data from

What automated decision making and/or profiling we do with user data

Industry regulatory disclosure requirements

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