WordPress 4.9.6 has been released. This was a focused release, a little different than other minor releases, in that it adds a system for a privacy policy to WordPress. While the only change to plugins has been our requirement that you not claim (or imply) 100% compliance in anything, the changes to privacy awareness are far reaching.
The tl;dr of the whole post is “You’re going to need to consider the impact of data collection in your plugins, even if you don’t collect anything.” So yes, I know it’s long, but please read the whole thing.
NOTE: We are not lawyers. We cannot tell you if what your plugin is doing is going to break a law. Please don’t ask us to try and figure that out for you. The purpose of this post is to make you aware of what’s going on, and give you a place to start with making your plugins better.
Does This Impact You?
Yes. This impacts everyone. Plugins are used internationally which means you actually do have to be aware of the world, Net Neutrality shenanigans aside. Your plugin could, in fact, cause someone to get in legal trouble. While that is technically their responsibility, you should be as aware as possible of the implications of your code and how it’s used.
Ask yourself this: Does your plugin…
- … write any private data of users (registered or visitors) to the database?
- … send any data to remote servers (i.e. act as a service or embed content)?
- … edit the comments form in any way?
If yes, then this absolutely, without a doubt, impacts your plugins.
If no, then this may still impact you, so please keep reading, because people are going to ask you about this.
Privacy Means Disclosure
If you’re a service, like you pull a library from a remote server, then you have to tell people that you pull data remotely. This has always been a policy, so if you’re not disclosing this now, please go fix it right away. But you also need to tell people the obvious things, like embedding content via your plugin means the site administrator is consenting to the embed terms of that service.
An example for you. Let’s say you have a plugin that embeds YouTube playlists. Your plugin should be clear “This plugin embeds YouTube Playlists.” We also recommend you include a link to YouTube’s privacy doc. It’s alright to say “By using the embed features in this plugin, you will be agreeing to YouTube’s Terms of Use.”
The same holds true now for data stored locally. If your plugin stores browser data of visitors, then yes, you need to document and disclose this. You can’t force site admins to publicize this in turn, but by making sure they know, you’re helping them determine what their own reasonable disclosure should be.
Some Code To Help
WordPress has gone the extra step to make it easier to make a privacy page and hook into it, both for users and developers. The moving parts you need to be aware of are the tool for users to request an export of all the stored data associated with them on the site. There’s also a tool for users to request erasure of that same data. Both tools include admin workflows to fulfill those requests. And there’s one to suggest what kind of text should be on someone’s site.
The handbooks have been updated to help you out here:
Also, while this is a little more aimed at theme developers, if your plugin happens to mess around with comments, please read the changes that affect themes, as there is going to be a new checkbox for comments.
Update Your Plugins
The tl;dr of all this is that plugins should…
- … disclose what user/visitor information it saves in the readme;
- … hook into the privacy page creator to inform people there too;
- … provide a way to export said information;
We aren’t (currently) changing any policy to require all this. At the same time, I strongly recommend at the bare minimum everyone put a privacy policy in your readme. Even if you don’t save any data and you don’t send anything, make a Privacy Policy anyway and tell people that.
Why? At the very least, it may stop people from asking you “Is this plugin collecting any data?” which saves you time. But more importantly, this is to protect yourself. After all, if people come through with a 1-star review that you caused them to become non-compliant because you didn’t disclose local data collection, well, that would be a very justified review.
#core, #guidelines, #privacy
