GDPR Information

Overview

The EU General Data Protection Regulation (GDPR) — designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy (see EU GDPR website) — went into effect on May 25, 2018. It primarily affects schools in the EU, but has wide-ranging implications for any school that stores or interacts with the data of EU citizens. Veracross has always safeguarded the data of all school constituents and is responding to this legislation with tools to empower schools to comply with the law. This article details GDPR-related data consent tools in Veracross:

• Consent policy management
• Consent collection tools
• Profile Export tool

To access these tools, users must have either the Data_Privacy_Admin or Data_Privacy_Usersecurity roles. These roles are never granted by default and may be combined with the System Administrator (SysAdmin) security roles, if needed.

Also see the article on recommendations for deleting person records with certain person roles.

Data Consent Section on the System Homepage

To manage data consent policies and actions, navigate to the Data Consent section on the System homepage. Several links are provided:

• Consent Policies: View a list of all consent policies
• Add Consent Policy: Add a new consent policy
• Add GDPR Action: Add a new GDPR-related action. The only one currently available is the Profile Export.
• GDPR Action Log: View a log of GDPR actions.
• Batch Add Data Consent Policy: Similar to other batch add functions on the System homepage (e.g., Add Profile Code to Multiple People), add data consent records to multiple people.

Data Consent Policies

Schools can create and manage as many data consent policies as they need, e.g., one set of policies for admissions families and one for current families. Versioning can be accomplished by creating new policies to which families must consent again. View existing consent policies with the Consent Policies link and add new ones with the Add Consent Policy link on the System homepage.

Consent Policy Data

Data consent policies are comprised of several elements:

• A description (name) of the policy, status, and begin/end dates. Use the status (active, inactive) and begin/end dates to manage the duration of particular policies.
• Policy items, listed on the General tab, which can be used to track the actual policy items — data fields and business processes — to which people are consenting. Add new policy items with the Add Record button.
• The text of the policy, displayed externally and details exactly what the person consents to. This is what is seen by constituents when they are prompted to consent. View and edit the text on the Policy Text tab. It is recommended to include the applicable dates in the full policy text or description, since constituents do not see the begin/end dates.

Finding Consent Records

On Person Records

Data policies to which a person has consented are displayed on the Consent Records tab of a person record. All data policies are listed, along with consent date and header information about each policy: description, policy text, status, and begin/end dates. The name of the most recent policy consented to is displayed in the header field of the tab.

Search for Consented Policies

To search for policies to which people have consented, run a Find People query and pull in the Consent Policy function field. This function field displays the date on which a policy was consented. Apply criteria to desired fields to narrow the search results (e.g., use Role = Parent to find current parents), and apply the following criteria and parameters to the Consent Policy function field:

• Specify the data consent policy (required).
• Use the operator “is not blank” to find people who have consented to the policy.
• Use the operator “is blank” to find people who have not consented to the policy.

Consent Collection Tools

When considering data policy consent collection, there are two types of users:

1. New users entering the system through various means, e.g., the Admissions Portal or Online Event Registration. To gather data policy consent, fields can be made available on the forms themselves.
2. Existing users already in the system, e.g., current families. An ad hoc method of consent collection is available that can be sent to constituents via portals or Composer emails. Existing users are not able to complete this consent through registration forms.

Collecting Consent From New Users: Admissions Webforms and Online Event Registration

To add a data consent field to an admissions webform or online event registration form, submit a client portal request with two pieces of information:

1. The URL of the webform or event form to be updated.
2. The URL of the data consent policy in Axiom. Find existing consent policies via the Consent Policies link on the System homepage. Add a new one with the Add Consent Policy link.

Note for online event registration forms: The registration type needs to be either “Public and Veracross User” or “Public Only” because this method of collecting data consent only applies to new users.

Batch Add Data Consent

If consent to a particular policy is obtained outside Veracross (e.g., on paper forms handed in by parents at an event), that consent can be recorded in batch in Veracross. Read more about batch adding in Axiom. To batch add consent to data policies, navigate to the Data Consent section on the System homepage and click Batch Add Data Consent Policy. In the query design, apply criteria as needed:

• Add fields from the left pane and apply criteria to fields as needed.
• Do not select a Data Consent Policy or Data Consent Policy date, as those will be updated in the query results.

Run the query. From the query results:

1. Optionally, use the checkboxes to select individual records to update. If no records are selected, all will be updated.
2. Select Batch Update Records from the Action menu.
3. Select the Data Consent Policy field from the drop-down menu and then select the policy to apply.
4. In the second field, select the Data Consent Policy Date field from the drop-down menu and then select the date to apply.
5. Click Update to complete the batch update process.

When the procedure has run, the selected policy will be updated on the selected person records. Here is a video illustrating the batch add process:

Collecting Consent From Existing Users: Ad Hoc Collection

Collect data consent from users already in the system via ad hoc collection that can be linked in portals and in Composer emails. Regardless of the method, users are taken to a page that displays the text of the policy and a flag they can check to accept the data policy. To accept the data policy, users check “I accept the data policy” and then Accept and Continue, at which point the page reloads and a message replaces the buttons: “You have successfully accepted this data policy.” The screenshot here illustrates that process.

In Portals

To collect data consent in a portal, use the system shortcut link attached to a button:

• {system:data_consent:#} where the number (#) is the ID of the data policy to use.

Find the data policy ID on the Consent Policies link on the System homepage. Example: {system:data_consent:2} 

In a Composer Email

To collect data consent from any users in the system via email:

1. To select recipients, create and run a person query. The Person ID field must be included in the results.
2. Select Send an Email from the Action menu.
3. In the email creation window, select:
   • Recipient Person ID Field: Person ID
   • Channel: Data Consent Policy Link
   • Additional Merge Field: Person ID
4. Click Go and then Launch Composer.
5. Add a shortcut link in the Composer email (see next section).

These steps must be followed in order for the link to work properly.

• You must start the email from a query. Starting an email from scratch, even in the Data Consent Policy Link channel, does not work.
• You must select all three options in teh email creation window before launching Composer. Selecting the channel at this stage is not optional.

Add a Shortcut Link in the Composer Email

In the Composer email, add a shortcut link to a button or as plain text. If adding as plain text, be aware that the merged URL that appears in the email is very long.

• {data:data_consent_#} where the number (#) is the ID of the data policy to use.

Find the data policy ID on the Consent Policies link on the System homepage. Example: {data:data_consent_2}

Access Provided Via a Secure Token in the Email

Veracross generates a secure token link for each data policy link send to each user that is valid for 15 days. When constituents click the link, they are taken to a “frameless” version of the consent policy where they are given the option to consent. Because consent is connected to person records, once a person has consented to a data policy, if they access it again (e.g., by clicking a link in an email again or accessing it again in their portal), they can view the policy and see that they have already consented to it, but are not prompted to consent again.

Profile Export

If a constituent submits a request to see their personal data in Veracross, schools can use the Profile Export feature. To export personal data:

1. Navigate to the System homepage and click Add GDPR Action in the “Data Consent” section.
2. Select the person.
3. Select the action type Export.
4. Click Add GDPR Action.
5. Select Run Action from the Action Menu.
6. Refresh the page (or click the General tab) to reload the page and see the results of the action.
7. To export the data, pop out the query and select Export to Excel or choose one of the printing options.

All GDPR actions are logged. To see them, navigate to the System homepage and click GDPR Action Log in the “Data Consent” section. The following video illustrates the process of adding the GDPR action: