GDPR when using the newsletter plugin?

[User]

When using the service “the newsletter plugin”, is personal data transmitted to another company or to the service provider or is it a self-hosted system?

[Michael]

Hello,

all the data stay on your own server. It’s completely self-hosted.

[qra]

Why aren’t the emails of newsletter subscribers encrypted as required by the GDPR?

[Michael]

Hello,

where does Gdrp state this?

Michael

[qra]

I don’t know if it is mandatory o reccomended, but here:
https://www.privacy-regulation.eu/en/32.htm

[Michael]

Hi,

don’t worry we are well aware of GDPR’s regulations. That is a recommendation, anyway all data is in your hands and nothing is stored elsewhere rather than your own server.

thanks
Michael

[Paul van Rossem]

The GDPR simply requires to store sensitive data (like names and email addresses) in a safe manner. This is a requirement, not a recommendation. If your WP site is ever hacked (which is not unlikely for WP) and you didn’t encrypt your data as a security measure, you may have a really big problem. Names, email addresses, gender, etc, should ALWAYS be encrypted. It is very easy to implement, the tools are just there. Just do it!

[Stefano]

The definition of sensitive data is here:

https://commission.europa.eu/law/law-topic/data-protection/rules-business-and-organisations/legal-grounds-processing-data/sensitive-data/what-personal-data-considered-sensitive_en

so it depends on what people collects about their subscribers. Since the data should be editable by subscribers, if the site is hacked (and 99.9% it means someone ha access to the files), they can exfiltrate the data and the encryption key that must be available in the code to have the site working.

Of course, there are many different measures one can put in practice, and a security assessment should be carried out as soon as one decides to collect specific/sensitive personal data. One option is not to use a mail marketing plugin, but use a secure software not publicly accessible and sync only the minimal data required to send a newsletter.

Another choice is to rely on a third-party mail marketing service to store or sync the data. They act as “data processor” (see the GDPR definition) and they may grant different levels of security and certifications (27001, nis2, …).

A note that may be relevant for someone reading this discussion: our plugin does not transfer personal data out of the site where it is installed. The only exception is when a third-party delivery service is used; in that case, the site owner should check the grants offered by that service when they sign up with that service.

[Author]

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