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:

  • 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.

  • In the second step, the user has to confirm the consent given. The user receives an opt-in email with links to a web page where the user can finish the double opt-in procedure (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 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:

  • Ask for a user’s consent before submitting the form by displaying consent checkboxes.

  • Send the user an opt-in email.

Adding and configuring the form

  1. Make sure that the page in which you want to create the form uses the Travel Standard page template.

  2. Add a (GDPR) Store data form component to the page.

  3. Click Edit in the Action bar to edit the form component.

  4. 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.

  5. Copy and paste this path to the Confirmation page field of the dialog and save the changes.

Adding a GDPR-sensitive field

  1. Add a new GDPR-sensitive input field component to the beginning of the form’s field set.

  2. In the input field’s edit dialog, label the Full Name field, name it fullname (this becomes the value of the internal JCR controlName property).

  3. On the Advanced tab, set Full Name field’s type to text.

  4. Open the edit dialog of the Consent definition component.

  5. Configure the option in which the user chooses consent duration in the Expiration options field. Use the <label>:<timeUnit>__<timeQuantifier> following format, where:

    • <label> represents the label shown for the option.

    • <timeUnit> defines the time unit. Use 1 for year, 2 for month or 10 for 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 to enter the following in the field:

      24 hours:10__24
72 hours:10__72
1 month:2__1

  6. 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.

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 (it 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.

  1. Open the visitor-manager module configuration at /modules/visitor-manager/config/personalFields.

  2. 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.

Making an existing form GDPR-compliant

In this section, we assume that you already have a form with a text input field labeled Full Name, internally fullname, and you 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.

  1. Select the form and change its template to (GDPR) Store data form.

  2. In the next step, switch to the Opt-in Email tab and configure the parts of the opt-in email.

  3. 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 the superuser role, you can do that in the JCR Browser app:

Relocating the text input field

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.

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