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GDPR guidelines

Introduction​

Out of the box, the Simplicité platform software (referred as "the platform" in the rest of this document) does not manage any private data.

The only out of the box business object which has some potentially private data fields is the User business object level (see below), but out of the box the platform is only configured with anonymous technical users.

The platform is designed to process configured data which may include private information. Compliance with GDPR (RGPD in French) regarding any private data managed within Simplicité is the responsibility of the data controller. The following guidelines provide assistance for GDPR compliance.

Note: all data configured in the platform is physically stored in the configured database(s). These databases are external software components from the point of view of the the platform. In other words the platform itself does not store any data.

Business data​

When configuring business data (business objects and associated business fields), it is important to track and document whether the data is private. This can be done by explicitly indicating the privacy status in the description of the business object, business process, field or other relevant components.

Another approach is to extend the configuration of the system objects (e.g. the Field business object) to add some structured information to classify the type of managed data (e.g. mark each field as Personal, Private or Intimate). Once the configuration extension and classification data are implemented on fields, exports and reports can be generated based on this information.

Edit: As of platform version 4.0 release 21 such a basic classification has been added to the Field object. The field classification indicates whether a field contains:

  • Personal data (e.g. name, date of birth, ...),
  • Confidential data (e.g. bank account number, password, ...)
  • Intimate data (e.g. political preferences, ...)

The User fields indicated below have been classified as an example.

This basic classification can be extended as needed since this field is not used in the platform's core engine.

Users​

User data​

The User business object has several fields that can be considered as private data:

  • login (field usr_login) - required
  • firstname (field usr_first_name) - optional
  • lastname (field usr_last_name) - optional
  • picture (field usr_image_id) - optional
  • email (field usr_email) - optional
  • work phone number (field usr_work_num) - optional
  • mobile/cellular phone number (field usr_cell_num) - optional
  • home phone number (field usr_home_num) - optional
  • address (fields usr_address1, usr_address2, usr_zipcode, usr_city, usr_state nd usr_country) - optional

Note: out of the box the platform is only configured with 2 anonymous technical users (designer and public) the other users are business data as any other business data.

Business data user-timestamping​

Timestamped business objects have two technical fields (created by and updated by) which holds the login of the user who has created/updated the considered record.

It is possible to implement specific business logic to erase/anonymize this timestamping data if required.

Social posts​

The social posts (globals or associated to business object records) are linked to the User business object by the pstUserId reference field.

Social posts can be globally inhibited or at a business object per business object level.

It is possible to implement specific business logic to erase/anonymize this social post data if required.

Logging​

Database logs​

The platform's logging mechanisms are configured by default to use the login as string identifier of the user who is attached to the log entry.

In the log business object AppLogger records there is a text field that holds the login log_user.

Technical logs​

In the technical logs the login is present as plain text on each line. Ex (in this example the login is designer)

2018-08-28 15:35:00,479 INFO [com.simplicite.util.CronJob] SIMPLICITE|https://myapp.mysdomain.com||ICORECM005|designer|com.simplicite.util.CronJob|run||Job processed

It is possible to configure the default log4j2.xml file to change this behavior.

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