Warn about lifecycle deletion

akeeba / com_datacompliance

A tool to help you work towards EU GDPR compliance for your Joomla!™ site

GNU General Public License v3.0

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Warn about lifecycle deletion #14

Closed nikosdion closed 6 years ago

nikosdion commented 6 years ago

[x] canDelete must take a date; change plugins
[x] Change Wipe model to pass a date to canDelete
[x] User fields with pre-lifecycle notification emails
- date notified
- date the user is told their account will be deleted
- is this notification now invalid (the user took an action to invalidate it)?
[x] New CLI script for pre-lifecycle notification emails
[ ] Attach a copy of the user's personal information to the email
[x] Do not apply lifecycle deletion on non-notified accounts unless --force is set
[x] System plugin: When a user logs in check if their account can be deleted. If not, invalidate their notification record.

nikosdion commented 6 years ago

Regarding "Attach a copy of the user's personal information to the email": this is a bad idea which may be against the GDPR. Since these accounts are abandoned we are not entirely sure the email address still belongs to the original account holder or if it's forwarded to a different natural person (e.g. the department head being forwarded email from an employee who's been since fired). It's best that we let the user decide if they want a copy of the data, let their account expire or go ahead and delete it themselves.

nikosdion commented 6 years ago

Regarding "System plugin: When a user logs in check if their account can be deleted. If not, invalidate their notification record." Logging in means that it's an active account and won't be collected by the user lifecycle management. Therefore we have to simply remove the notification flag no matter what.