GDPR and Cflow

This article covers what EU’s GDPR is about, as well as the features and capabilities of Cflow that can help you build GDPR compliant custom apps/workflows.

Note: The content presented in this page is not to be construed as legal advice. Please contact your legal counsel to learn how GDPR impacts your organization and what you need to do to comply with GDPR.

What is GDPR?

The European Union (EU)’s General Data Protection Regulation (GDPR) is a new regulation that came into effect on the 25th of May, 2018. It aims to harmonize the data privacy laws across the EU, and (in particular) protect the rights of residents of the EU with regard to the processing of their personal data. It recognizes the data privacy rights of EU residents and lays down rules relating to the processing of their personal data.

At its core, the GDPR aims to give EU residents full control over their personal data.

What is Personal Data?

In the context of GDPR, personal data is any data that can directly or indirectly help identify a natural person. This includes, but is not limited to: name, address, phone number, email address, IP address, habits, and photos.

When and Where Does GDPR Come Into Play?

GDPR applies for any activity that collects or processes the personal data of EU residents. It does not matter if the said activity takes place inside the EU or not. GDPR has a global reach.

Why Be GDPR Compliant?

EU’s GDPR came into effect on the 25th of May, 2018. It is legally binding. The concerned Supervisory Authority (as defined by GDPR), may fine the non-compliant person or organization up to 20 million Euros or 4% of their annual worldwide turnover from the preceding year, whichever is higher. Levying a fine is in place for two reasons:

  • A deterrent, so that Data Controllers and Data Processors act responsibly, and adhere to GDPR’s guidelines
  • A compensation for the persons who have suffered material or non-material damage as a result of an infringement of GDPR

Key Roles that GDPR Identifies

  • Data Subject: A resident of the EU from whom, or about whom, data is collected and/or processed
  • Data Controller: The person or organization that defines the purpose and means of collecting and processing data
  • Data Processor: The person or organization that processes the collected data on behalf of the Data Controller

In this context, the following two scenarios come into play:

  • When you sign up with Cavintek’s Cflow, you act as the Data Subject and Cavintek acts as the Data Controller.
  • When you use Cflow to build an app, the natural persons that you collect data about (the users that you share your app with or use your app, for instance) act as the Data Subjects for that app. You act as the Data Controller and Cavintek acts as the Data Processor

Addressing rights of Data Subjects

The following are the Data Subject Rights that GDPR identifies, and how Cflow helps you address them in your apps/workflows:

Right to be informed: Add a Large Text Box field to your form

  • The Data Subject has a right to be informed on how their personal data was, is, and will be processed. By adding a Large Text Box field to your form (next to the fields in which you’re collecting their personal data), you can explain why you need said data, what you will be using it for, and how it will be processed. You can also insert a hyperlink (in the note) to your organization’s privacy policy.

Right to accessright to erasure, and right to be forgotten: You need to forward the requests you receive from your users to Our Support team will analyze the request and guide you on how to act on it.

  • With their right to access, the Data Subject can demand Data Controllers to furnish the following: the personal data (of the Data Subject) that was collected and processed, how it was obtained, how it is processed, and to whom it was shared with — all the details from point of collection to point of storage
  • With their right to erasure, the Data Subject can demand that Data Controllers erase all their personal data
  • With their right to be forgotten, the Data Subject can demand for their data to be completely erased

Right to rectify: Users can edit their records by accessing the respective reports.

  • The Data Subject has a right to obtain from the Data Controllers, without undue delay, the rectification of inaccurate personal data concerning them, and complete any incomplete data point.

Right to objectto processing of their personal data: Add a Confirmation checkbox to your form

  • Use separate Confirmation checkbox fields to capture the Data Subject’s consent to process their personal data and define your workflows such that these permissions are checked before they are processed. To give or take away their permission, the Data Subject can simply update the relevant field accordingly.​

Right to data portability: Data submitted by your users can be exported as spreadsheets and PDFs

  • The Data Subject has a right to receive all their personal data, submitted to the Data Controller. To do this, users can simply export their records from reports.

Implement some best practices

You can leverage the features and capabilities of Cflow to implement the following in your apps:

Denote fields that contain personal data

Mark the fields that contain personal data with an appropriate Help Message Text that clearly mentions that the user will be entering some personal data.

Encrypt data

Upon enabling this field property, the data your users enter in that field will be stored in an encrypted format.

Getting consent

Data Subjects have a right to be informed on why your app, or a form in your app, is collecting data, and how it will be processed. Also, as a Data Controller, you may need to show if your users gave their consent for this. Here’s how you do it:

  • If consent is required along with the data a form is already collecting, then add a Large text box field (which will display information on why you need to collect certain data points, and how you will process them), and a Confirmation checkbox field (set to mandatory) that lets your users give their consent.
  • If consent is required on the app level, add a new form and use the combination of Large text box and Confirmation checkbox fields as given above.
  • To let your users know what they consented to, you can send them an email saying they’ve given their consent (and copy-paste the Large textbox field’s content in the email message).
  • Another option is to use the Terms and Conditions form field. This comes with a Large Text box and Checkbox combo.