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Hanne B. Stegemüller

Data Protection Policy in Danish

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Hanne B. Stegemüller

I'm educated lawyer, so I also have focus on GDPR, rules and regulations. Therefore I've translated Data Protection Policy file into Danish, so that it is almost according to Danish (means European) rules.

On my own I have on added this - so this is not part of the standard file (it is my own "invention"):
 

Quote

 

"The Danish Data Protection Agency's guidance on the rights of data subjects:

Page 45 of a total of 59:

"In its practice, the Danish Data Protection Agency has stated that genealogists are generally allowed to publish family trees with quite insensitive (banal) information such as names, birth and death years without the consent of the data subjects. This is because the legitimate interests of genealogists in publishing the family tree in these situations generally exceed the interests of the data subjects."

 

Almost because: According to the Danish/European rules it should to be possible to accept some cookies and reject others before entering the site. TNG does not offer this possibility. You can only accept, because the button says "OK" and nothing else.

Conclusion: You can download and use my file if you like. It is so precise as possible according to the rules. But it is not 100 percent legally. But you will show your customers that you have done so much as possible.

data_protection_policy.php

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RickM

@Ken Roy

This info may be better placed on the Wiki.. Are you able to do that, or may I try with the support of yourself..

I'm sure @Hanne may be able to do so, however I am happy to help her out..

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Ken Roy
3 minutes ago, RickM said:

This info may be better placed on the Wiki.

Sorry, but this needs to be sent to Darrin to include with the TNG versions, if the distributed version is not accurate for Danish

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RickM
9 minutes ago, Ken Roy said:

Sorry, but this needs to be sent to Darrin to include with the TNG versions, if the distributed version is not accurate for Danish

Ok Thanks Ken..

I'll see what Hanne says about the accuracy of the distributed version for Danish.

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Hanne B. Stegemüller
10 minutes ago, Ken Roy said:

Sorry, but this needs to be sent to Darrin to include with the TNG versions, if the distributed version is not accurate for Danish

Super both RickM and Ken Roy

I hope I do not do something wrong, as that is no my intention.

If you both have the feeling it is more correct to contact Darrin directly I'll of course do that. I just thought, that the more questions we could  handle by ourselves the happier Darrin would be.

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RickM
13 minutes ago, Hanne said:

Super both RickM and Ken Roy

I hope I do not do something wrong, as that is no my intention.

If you both have the feeling it is more correct to contact Darrin directly I'll of course do that. I just thought, that the more questions we could  handle by ourselves the happier Darrin would be. 

Greetings Hanne,

No you have done nothing wrong. Indeed you have done good yet again.. I felt it was worthy of going on the Wiki site because it related to GDPR and the info was aimed at Danish folks.. Ken is suggesting IF the data-protection-policy.php file in the Danish Language folders is not correct or could be better translated as it seems you have done, then perhaps Darrin should include it in later releases of TNG.. I think it might be the right thing to do..

As for handling questions etc ourselves again you are correct, sometimes though it is good if Darrin is involved so to speak..

 

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Hanne B. Stegemüller
8 minutes ago, RickM said:

Greetings Hanne,

No you have done nothing wrong. Indeed you have done good yet again.. I felt it was worthy of going on the Wiki site because it related to GDPR and the info was aimed at Danish folks.. Ken is suggesting IF the data-protection-policy.php file in the Danish Language folders is not correct or could be better translated as it seems you have done, then perhaps Darrin should include it in later releases of TNG.. I think it might be the right thing to do..

As for handling questions etc ourselves again you are correct, sometimes though it is good if Darrin is involved so to speak..

 

Great - and thanks RickM Greetings to you as well!

At first: Thanks for not having done anything done wrong. Sometimes I think, that though we speak/write in more on good English, there is something "beneath" the simple words. Probably I have something to learn here!

On private message I have  connection with a user, who knows a lot more about GDPR than I do. When we have agreed what is correct, we can correct about Darrin about what i about  is correct according to the European Law. The problem is that it might need some coding.

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RickM
6 minutes ago, Hanne said:

Great - and thanks RickM Greetings to you as well!

At first: Thanks for not having done anything done wrong. Sometimes I think, that though we speak/write in more on good English, there is something "beneath" the simple words. Probably I have something to learn here!

On private message I have  connection with a user, who knows a lot more about GDPR than I do. When we have agreed what is correct, we can correct about Darrin about what i about  is correct according to the European Law. The problem is that it might need some coding.

We both have something to learn about the language barrier. I believe the hardest part is English is so wide and quite often indirect, unlike a lot of other languages that are more direct and precise.

I'm sure Darrin will be able to sort the coding issue if need be, however I'm available to do what I can if I can.. <Smile>.

Have a good one Hanne..

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Hanne B. Stegemüller
2 minutes ago, RickM said:

We both have something to learn about the language barrier. I believe the hardest part is English is so wide and quite often indirect, unlike a lot of other languages that are more direct and precise.

I'm sure Darrin will be able to sort the coding issue if need be, however I'm available to do what I can if I can.. <Smile>.

Have a good one Hanne..

Thanks a lot - same to you RickM

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tngrlkrz
2 hours ago, Hanne said:

Super both RickM and Ken Roy

I hope I do not do something wrong, as that is no my intention.

If you both have the feeling it is more correct to contact Darrin directly I'll of course do that. I just thought, that the more questions we could  handle by ourselves the happier Darrin would be.

OK for solving here for those on the forum, but even more important is that Darrin is alerted because otherwise the next update will not contain the suggested corrections.

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Hanne B. Stegemüller
6 minutes ago, tngrlkrz said:

OK for solving here for those on the forum, but even more important is that Darrin is alerted because otherwise the next update will not contain the suggested corrections. 

That is correct! It also means that  I have the time to communicate with ""Andreas"  from somewhere in Germany who knows a lot more about GDPR that I do. I don't like to disturb Darrin before it is necessary.

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Katryne

Good evening everybody !

I am (was) too a lawyer by trade, and I had discussed too with Darrin about GDPR. I even asked him to include the TNG texts about GDPR in my main site, which is coded by an Italian ... lawyer. We have observed slight variations in the interpretation of the GDPR in different European countries and I have not found in France the mention of the legitimate interests of genealogists that Hanne notes.
This change in the text would therefore only apply to the Danish text.

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Hanne B. Stegemüller
12 hours ago, Katryne said:

Good evening everybody !

I am (was) too a lawyer by trade, and I had discussed too with Darrin about GDPR. I even asked him to include the TNG texts about GDPR in my main site, which is coded by an Italian ... lawyer. We have observed slight variations in the interpretation of the GDPR in different European countries and I have not found in France the mention of the legitimate interests of genealogists that Hanne notes.
This change in the text would therefore only apply to the Danish text.

Good morning Katryne

Yes I do agree that the legitimate interests of genealogists that I note, can only be implemented in the Danish Data Protection Policy as it is an interpretation of GDPR made by a Danish authority. It would be so nice if there would be EU-rules about this, as of course Darrin can not code a set of rules per country. So maybe the solution is, that each of us who are interested in this matter add our file to a page where customers can download them.

But some of the rules are a part of GDPR itself, and that is i.e. that it should be possible to accept some of the cookie and reject others before entering the site. The only possibility "OK", does not make the user compliant.

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Hanne B. Stegemüller

Good morning everybody!

This is a fantastic forum - where everybody is helpful and kind.

My preliminary conclusion is:

  1. I'll contact Darrin with a link to this thread
  2. I'll tell him not to take action to the European sets of files till I have come closer to what it needs to be compliant. I will learn this from Andreas in Germany who has worked professionally with GDPR for many, many years. I myself only know what I've read here and there.

What do you think about this?

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RickM

Hanne, brilliant conclusions and ideas.

This is a great step forward for TNG IMHO. It means as you have already stated 'It shows one is taking care of customers'. Good for Darrin because he knows he is getting some pretty good policy on GDPR, good for you as you learn a little more about TNG and the inner workings, and good for ALL because they know that (at least within Europe) they are getting good policy info out of the box, from fellow TNG users who are taking care..

At your service

 

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Hanne B. Stegemüller
2 minutes ago, RickM said:

Hanne, brilliant conclusions and ideas.

At your service

 

Thanks a lot RickM. It is always nice to be "brilliant".

You are perfectly right: there are many great learning processes in a process like this one!

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Hanne B. Stegemüller

I have written this to Andreas from Germany:
 

Quote

 

Please read up on this thread: https://tng.community/index.php?/forums/topic/16114-data-protection-policy-in-danish/

It would be fantastic if you and I together can help Darrin with a general version of Data Protection Policy that makes users of TNG in EU compliant with GDPR.  I have absolutely no idea of making something that takes care of local rules here and there in the different countries. Just making something that can be used in all European countries, that TNG-users can adjust to local rules an legislations if they want to. I do not know how big the task is.

You are much more experienced with the rules and regulations than I am.

Are you interested in collaborating with me about that?

 

 

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HelwegA

Dear all,

this is Andreas Helweg from Northern Germany - Hanne already introduced myself in the forum in his posts on the topic of GDPR. Just registered and here I am now...

I have just retired and worked - not as a trained lawyer - but nevertheless for over 10 years as a data protection officer for a large German corporation in Hamburg. During that time I learned a lot about legal issues and especially about data protection on the internet and websites.

At the moment I am just about to resume my family research with TNG - which I interrupted about 10 years ago by adapting my self hosted website on my own server.

And, of course, my primary concern is the legal framework for the website in the EU. I have (not yet completely translated) but terms of use, privacy policy, contact form and for Germany especially important, the imprint adapted to our German/ EU-legislation. At the moment I am in the process of formulating basic thoughts on private genealogical research. Of course this takes some time and it is still going on...

I am also not at all satisfied with the privacy and cookie settings in the TNG standard configuration. As far as I can, I have made adjustments, but will - when I am ready on that one - make some suggestions to Darrin or even better before that, here in the forum to incorporate the European requirements into TNG, so that it could be discussed beforehand.

Briefly about cookies: I have eliminated Google from my website (instead I use OSM) as far as possible, so only technical cookies remain in TNG (you can read about that in my Privacy Policy - I will check the translation to the English Version asap), which currently can be set in the EU without consent, so this nonsensical OK-button from the standard Cookie-Banner from TNG for the EU is not necessary in my case (if you have Google Maps or Google reCaptcha or other tools implemented in your site, you need a cookie banner - but this must be built differently than the cookie banner from the TNG standard!)

So please give me some more time, I will then make some suggestions that apply to the EU countries. Local peculiarities from individual countries - as Hanne has written, for example, about the Danish regulation on private genealogical research - I can of course not take into account.

Best
Andreas

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RickM

Thanks for the Introduction @HelwegA

Whilst this may not have a direct impact on me, being in NZ, I believe I still have to comply and offer various protections and cookie settings for European visitors, so will be watching this space..

Between Hanne and yourself I'm sure something great will come.

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HelwegA
vor 4 Minuten schrieb RickM:

Between Hanne and yourself I'm sure something great will come.

@RickM Thanks! Give us some time - the topic from European perspective is not as easy as it might be on a first glance - but yes - I hope that the community can proftit a little from the ideas

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Hanne B. Stegemüller
1 hour ago, HelwegA said:

@RickM Thanks! Give us some time - the topic from European perspective is not as easy as it might be on a first glance - but yes - I hope that the community can proftit a little from the ideas

Good to have you here HelwegA. Thanks a lot!

I am sure we can do some good work together.

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HelwegA

@Hanne Yes - now "I'm on board" - ahead of schedule

If you like, you can now read the privacy text in Danish, English and Dutch (and of cause in German) - I translated the text earlier this afternoon. The next few days I will finish my thoughts on private genealogy and then write a draft that contains the essential points on EU data protection - in it I will then refer to my texts - then we can discuss.

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Katryne

Folloming this thread. I am interested.

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HelwegA

Preliminary remark:
I have worked for many years as a data protection officer in a large German corporation, but I am not a trained lawyer.
Everything that follows is written to the best of my knowledge, but I will not assume any liability for the individual implementations etc. and for any risks and legal disputes of individual users that may arise from these suggestions; the subject matter is too complex for that and the respective situations are too specific.

Everything that follows now, I write from a European perspective:
Within the EU, the same data protection legislation according to GDPR has applied uniformly since May 2018, so that uniform rules are also in force for all EU countries. The GDPR leave room for national opening clauses in some places - I do not take these into account either; and due to Brexit, the UK is currently also in a transition phase towards new national data protection legislation. In addition, there are now court rulings - some of them very far-reaching - from different instances that are leading the way in interpreting individual issues.

The GDPR is generally referred to as the 'world-wide-gold-standard' of data protection legislation. However, this is far from correct; there is definitely potential for improvements to the current regulation and in some cases simpler rules apply in other countries. Nevertheless, we in the EU are bound by the applicable laws.

Why this extensive text on data protection? There is some wording (e.g. in the provided privacy policy from TNG) and settings (cookies...) in the currently delivered standard of TNG that do not comply with the corresponding legal situation; this should be corrected with a future update.

Depending on prior knowledge and desire in the community, I would describe some introductory basic topics (what is personal data, basic GDPR principles, technical and organizational measures, accountability, third country transfer (Schrems II - ruling and TIA) and where to find relevant information. In addition, some website-related topics are then important (cookies, security, information obligations/ privacy policy), which can then be taken over into the wiki at a later stage, for example, on the one hand, and given to Darrin as an idea for an update of TNG, on the other.

I'll wait for the feedback and will then pick out individual points and post something about them in the next few days/ weeks.

What I will not do is an individual consultation and I will refer essentially (with some exceptions) to the TNG standard.

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Katryne

Nothing was simple, everything is getting more complicated.

 

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