Maintaining data privacy

Overview

Complying with data privacy regulations is not a one-time task. Once a Moodle site has been configured to implement data privacy policies, the site must be monitored regularly to respond to data requests and other privacy-related events.

Responding to data requests

Users may request a copy of all data related to the user that is held on the site. Users may also request that all data related to them is deleted from the site. An email will be sent to the address designated in the Data Privacy Offer setup, and the request will be placed in a queue for approval.

The Data Privacy Officer or a designate should monitor the queue of such requests to approve them in a timely manner. The Privacy Officer can respond to data requests as follows:

• Go to 'Data requests' in the Site administration (or follow the link in the data request notification).
• In the Actions dropdown, select View, Approve, or Deny as appropriate.

For more information, see Data requests.

Agreeing to policies on behalf of users (e.g. minors)

An admin or any user with the capability Give consent for policies on someone else's behalf can give consent on behalf of minors or when a written consent was obtained offline. For more information, see User agreements.

Reviewing user policy agreement acceptances

It may be necessary to monitor a site to determine who has agreed to a policy and who has not, especially if a policy has been changed. Failure to agree to a policy will prevent the user from logging in. The capability to check policy agreements may be necessary for technical support personnel responsible for troubleshooting login problems. For more information, see User agreements.

Reviewing and deleting content past retention date

As part of configuring the Moodle site for data privacy, retention periods have been set for each "purpose" of data. As these retention periods come to an end, data is queued for deletion after approval by the site Data Privacy Officer. See Data deletion for more information.

Keeping policies up to date

Regulations and institutional policies can change over time, and this should be reflected in a site's user policies. If a change is made to a policy, a new version will be created. Users will need to agree to the new version before their next login. Policies can be disabled, but if at least one user has agreed to a policy, it cannot be not deleted. For more information, see Manage policies.

Breach notification

The GDPR also requires organizations to implement appropriate policies, protect personal data by using security protocols, conduct privacy impact assessments, and keep detailed records on data activities. The EU GDPR places strict control on where personal data is stored and how it is used.

Under the GDPR, organizations are required to report data breaches to the appropriate authorities if it will “result in a risk for the rights and freedoms of individuals”. The breach notice must be done within 72 hours of first having become aware of the problem. If there is a high risk of harm, organizations must notify any affected data subject as soon as possible.