RGPG / GDPR compliance

[NicoDucou]

To make Chamilo ready for GDPR (https://www.eugdpr.org/) and ease organization to comply with GDPR there should be an extension to Chamilo.

For the user to accept the use of it's personal data in Chamilo organization should enable and configure the "terms and conditions" functionality from the administration configuration parameters.

Then there should be:

• a place for each user to be able to see all the data that chamilo store about itself.
• a possibility to export all those data
• a possibility to remove own account

To do this there should be a new link on the social network page (main/social/home.php) in the profil bloc below "edit profile" add a link called "Personal data" that open the personnal data page.

Personal data page

This page shows the data of the current user (each user can only see its own data).
It will have different blocs to organize the information and at the top 2 buttons :

• Export data (that will enable to export all the datas from the page to a csv file including the date of the day)
• Remove account (that will open a window with message "If you remove your account all your data will be lost, you will loose your acquired skills, certificates, results, grades and all access to the plateform. Are you sur you want to proceed ?" and if validated then it removes the user).

1) Identity

It shows a long page of data with this introduction (replace DATE by the date of the day):
Here is the list of all your personal data as of today (DATE):

Field	Personal data
field1	value1
field2	value2
...	...

Which field would be in this table ?
All the fields that are presented on main/admin/user_edit.php?user_id=X (where X is the user_id of the current user). This should get us all the info we have in the user table and in the user extra fields.
There will also be an IP field with all the IPs that correspond to that user that are stored in
track_e_access, track_e_course_access, track_e_login and track_e_online.
There shoulb be a field Class to show all the classes the user is subscribed to.
If it's a multiURL plateforme and that the user have access to more than 1 URL then add a URL field and indicate all the URLs he has access to.

2) Social Network

This will show all the information related to this user that is related to the Social network.

• The list of social groups that the user is in and for each the messages that the user sent.
• The list of user he is friend with and for each one the messages that were sent by the current user

3) Courses and Sessions

• The list of sessions (name/title) the user is subscribed to or related to (coach for example)
  • The list of courses (name/title) in this session the user is subscribed to (or related to (coach for example)
    • The list of documents the user uploaded to this course
    • The list of exercises and result the user add in this course
    • The list of forum the user has created or participated in and the messages he sent
    • The list of learning path and the statistics for every item
    • The list of attendances the user is referenced in (table c_attendance_sheet) and the result of its attendance indicating if he was present or not (table c_attendance_result)
    • The list of event created by the user
    • The list of file sent or received through dropbox (c_dropbox_file, c_dropbox_person) with the feedbacks (c_dropbox_feedback, c_dropbox_post) sent by the user
    • The list of groups the user is part of with its role and all the documents, exercises, forums, chats, assignments, events and wikis of this group
    • The list of message sent by the user in the course chat
    • The list of assignment created or submitted by the user with its marks and comments if there are.
    • The list of survey the user participated in with for each on the list of the user's answers
    • The list of the current user's contribution to the wiki
    • The list of notes in the notebook
    • The list of posts in the the course Blog
    • The user's course category ordering (from user_course_category table)
• Add a "no session" entry
  • The list of courses (name/title) with no session the user is subscribed to or related to (coach for example)

4) Skills and certificates

• The list of the skills acquired by the user
• The list of feedback sent by the user on skills acquired by other users
• The list of certificate generated for the user

5) Personal Agenda

• The list of all the event created by the user for its personal agenda.

6) Tickets

• The list of tickets created by the user or that the user participated in
  ** The list of post by the user in each ticket

7) Statistics

• The list of information that is related to the user and that are stored in the track_e_* tables and user_rel_course_vote

8) API

• The list of API registered in user_api_key

[jderriks]

The possibility to remove own account option is not always required if an organisation has conflicting legal obligations to keep student data (like quiz results or assignments) for a certain period. You can say that when a student uploads something a copy is given to the school just as if it were an email. The plugin should be configurable to handle different cases. GDPR deadline is May 25th of 2018...

[ywarnier]

Hi @jderriks,
We will definitely miss the deadline (not by much, but we won't be able to do a proper Chamilo release by then).
The option is already there to let users unsubscribe, so the institution can choose (whether or not to let them do that). We want to make that available on the same page if enabled.

[jderriks]

Unsubscribing from a course is something different than "remove own account with all associated logging data". Chamilo does not have this feature (for users) and GDPR is not that specific. I think an email to the admin who deletes the account within x days is also a valid procedure. Is everything realy deleted when an admin removes a user? Then replace "delete" with "download" for the feature requested by this issue :-)

[ywarnier]

Unsubscribing from a course is something different than "remove own account with all associated logging data"

That's why these are 2 different features in Chamilo.

[ywarnier]

We've added an anonymization feature to the upcoming version (see #2598). This blanks the IP address and all personal data we know of, but leaves the anonymized account there for statistical purposes.

[jmontoyaa]

I think we should create a tool in the course to get this data (per course).
Later we can make a loop of this function for all the courses/session to get all content ...
This screen it's going to be really big, better we should handle it with ajax requests ...

[ywarnier]

Why a tool in the course? This is user-related data, so I'm not sure doing this as a tool would help (there is no use case where the user would want to have his/her data only from one course).
Maybe having a mother class/interface for all course tools that defines a method to return all of this tool's data for a given user, but then each tool should be a class that inherits that mother class, and this is not the case yet, so let's postpone that to a later time when we need it more.