GDPR and forms
This page describes how to create a new GDPR-compliant form as well as how to adapt an existing form (containing a field where users may enter personal data) to comply with GDPR requirements.
The examples on this page make use of the Privacy module and the Travel Demo.
Simple form processing compared to GDPR-compliant form processing
In an ordinary form, the data entered in the input field is usually processed directly upon hitting the submit button on the form.
A GDPR-compliant form needs to follow a more complex procedure called double opt-in:
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A form that contains personal data has to be submitted together with the user’s consent for the processing of such data. This is usually done via checkboxes which the user has to tick off before submitting the form.
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In the second step, the user has to confirm the consent given. Typically the user receives an opt-in email with links to a web page where the user can finish the double opt-in procedure, that is confirm or reject the consent.
In the example below, we assume that we have a text input form field
called fullname that must be handled in compliance with GDPR.
privacy module writes into the contacts app
Visitors app adds also contacts
In the Magnolia DX Core Travel Demo, the contacts workspace is
registered in the configuration of the Privacy module for demonstration
purposes of dealing with personal data. This means the Visitors app
interacts not only with the visitors workspace but also with the
contacts workspace, which is otherwise primarily used by the
Contacts app.
GDPR data is stored on public and must be synchronized on clusters
Data is stored on the public context.
| Synchronization between public nodes may be required. |
The record of consent for form-based data in the visitors workspace is
created on the public Magnolia instance, never on the author instance.
This is also true for referenced content, for instance in the contacts
workspace.
You must synchronize the consent records stored if you use several
public instances. The instances, or in our sample implementation at
least the visitors, pendingContacts and contacts workspaces, must
be clustered in order to share accounts between the different instances.
Alternatively, implement observation-based synchronization to replicate
visitor and contact data across instances.
Creating a GDPR-compliant form
In this section, you create a new GDPR-compliant form. You need the knowledge gained here in the second section where you already have a form and want to adapt it for GDPR.
The Magnolia Travel Demo bundle comes with a sample form component
template called (GDPR) Store data form, which is provided by the
privacy-sample submodule and designed for the purposes of GDPR.
This component template is preconfigured to:
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Ask for a user’s consent before submitting the form by displaying consent checkboxes.
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Send the user an opt-in email.
Adding and configuring the form
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Make sure that the page in which you want to create the form uses the Travel Standard page template.
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Add a (GDPR) Store data form component to the page:
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Click Edit in the Action bar to edit the form component.
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On the Opt-in Email tab configure the parts of the email which will be sent to the user in the second phase of the opt-in procedure:
The largest text area in the dialog is where you can define with FreeMarker variables how the main message of the confirmation email will look like. The body of this email message should contain hyperlinks to a consent confirmation/rejection page. The Travel Demo comes with a sample of such a page at/travel/contact/confirmation. -
Copy and paste this path to the Confirmation page field of the dialog and save the changes.
Adding a GDPR-sensitive field
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Add a new GDPR-sensitive input field component to the beginning of the form’s field set.
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In the input field’s edit dialog label the field Full Name, name it
fullname(this becomes the value of the internal JCRcontrolNameproperty).
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On the Advanced tab, set Full Name field’s type to
text. -
Open the edit dialog of the Consent definition component.
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Configure the option in which the user chooses consent duration in the Expiration options field. Use the following format
<label>:<timeUnit>__<timeQuantifier>where
<label>represents the label shown for the option.
<timeUnit>defines the time unit. Use1for year,2for month or10for hour.
<timeQuantifier>defines the actual length of consent for the time unit specified.
For example, if you want to allow the user to choose from consent durations of 24 hours, 72 hours and 1 month, you need enter the following in the field:24 hours:10__24 72 hours:10__72 1 month:2__1
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To set a default value to be selected when the form is loaded, enter the part that follows the colon in the Default expiration value field, for example
2__1.
The actual selection box is rendered like this:
Updating Privacy module configuration
Since this step is done in the
Configuration app, you need
the superuser
role to
access the app and change the configuration.
Both the email field, which comes preconfigured with the (GDPR) Store
data form template, and the fullname field, added to the form’s field
set, must be database names registered in the system for GDPR-compliant
data processing. This is done in the configuration of the Privacy
module.
Open the visitor-manager module configuration at
/modules/visitor-manager/config/personalFields.
Add the newly added fullname field name as a property (which is in
fact arbitrary) and value under the name/fieldNames node, which is
already present in the configuration:
At this point, the newly created form is GDPR-compliant. The user is asked to give consent to process the data entered:
Making an existing form GDPR-compliant
In this section, we assume that we already have a form with a text input
field labeled Full Name, internally fullname, and we want to adapt
to comply with GDPR:
Changing and configuring the component template
First you need to change the form’s template to use one that is designed for GDPR. In this example, we use the template called (GDPR) Store data form again.
Select the form and change its template to (GDPR) Store data form:
In the next step, switch to the Opt-in Email tab and configure the parts of the opt-in email:
After saving the changes the form contains two field sets:
Relocating the text input field
Now you have to make the Full Name field in the first field set a
member of the other field set. With superuser role you can do that in
the JCR Browser app:
After this operation, the Full Name field is located next to the Email field:
Updating Privacy module configuration
Again, the fullname field, added to the form’s field set, must be a
database name registered in the system for GDPR-compliant data
processing. Ask your system administrator to do this for you if don’t
have access to the Configuration app.
Open visitor-manager module configuration at
/modules/visitor-manager/config/personalFields.
Make sure that the relocated field’s fullname name is a property and
value under the name/fieldNames node , which is already present in the
configuration. If it isn’t there yet, add it there. The relocated field
is now also subject to the logic of the (GDPR) Store data form
template and hence the GDPR requirements. When submitting the page, the
user is asked to give consent for both text input fields in the form,
Full Name and Email: