Data Protection is based primarily by what are called ‘Principles’ so to start let’s look at the principles and how they interact in a WordPress perspective: (GDPR Ch II, Art. 5).

GDPR | Art. 5

Principles

  1. Personal Data shall be:-

GDPR | Art. 5

Principles

 

The principles are perhaps the most fundamental set of instructions when processing personal data under the GDPR they are detailed under Article 5 of the regulations.

 

  1. Personal data shall be:
Lawfulness, Fairness and Transparency

a. – Processed lawfully, fairly and in a transparent manner in relation to the data subject.

Just because WordPress facilitates (allows) processing of personal data, you cannot simply dive into it without having what they call a legal basis for doing so.

Processing personal data requires at least one lawful basis or if more that one lawful bases in order to be lawful under this principle.  If processing special category (sensitive), personal data then you will require additional lawful bases in addition to the ones for personal data.

This will be covered a little later on so don’t worry about it, just make a note of it for now.

Purpose Limitation

b. – Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes.

In WordPress terms if you collect an email address in order to send a newsletter – that was the purpose for which the individual volunteered their information, you cannot use the data for any other purpose without first seeking additional consent as it would not be being processed lawfully.

Data Minimisation

c. – Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Do you really need to be processing personal data which is no longer relevant to your current business model?  If the answer is no, stop processing, and take appropriate steps to securely remove it.

If you cease trading and the data remains, you are still legally responsible for it as Data Controller and so is the Hosting provider as Data Processor! 

Accuracy

d. – Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

So far as WordPress is concerned, best practice should be to have forms/processes in place to allow users/subscribers/customers to check and update their own data.  Remember that any corrections should be reflected in the data being processed by any data processors.

Storage Limitation

e. – Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject.

If you don’t need to process the data anymore – don’t, it can be a liability!.  If you have notified an individual that you will not be processing the data after a given period – don’t, it’s a liability and to continue to do so would mean non-compliance with the legislation.  If you do need to keep specific data for a longer period, such a the example given in this principle then look at some way of obfuscation (pseudonomynisation or anonymisation) .

Integrity and Confidentiality

f. – Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures,

2. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).

It’s a shame that this one is listed last within the principles as it’s the one most used in order to look at remedial action after a personal data breach.

So far as WordPress is concerned it’s about security, updates, maintenance and user roles – which is convered in another category on this site.