topic Betreff: GDPR Consent - Log evidence in GDPR

GDPR Consent - Log evidence

godaime — Wed, 06 May 2020 16:15:33 GMT

I'm trying to use an Hubspot Form inside my wordpress site. I'm using a checkbox to get explicit consent to collect personal data. I followed the instruction found here

https://www.hubspot.com/data-privacy/gdpr/product-readiness.

Under section "Consent" I read that

"An additional detail on notice: if you need to link out to additional notice provisions (like privacy notices), you can do so using hyperlinks in forms.
Once Ana submits her information, we will store a copy of the notice that Ana was provided, information about which consent she provided, and the timestamp of the interaction."

So I placed a link to my privacy policy page in my form, to demonstrate exactly what kind of consent I received.

If I try to use the form, I get all data correctly in Hubspot. I find a new account, with name and email provided. I also find a property "Legal Basis for processing contact's data" that is correctly set to "Freely given consent".

My problem is that I don't find the copy of the notice stored, that is mandatory to be fully GDPR compliant.

Am I missing something or doing something wrong?

Thanks for any help.

Betreff: GDPR Consent - Log evidence

JessicaH — Tue, 12 May 2020 08:55:41 GMT

Hi @godaime,

Thanks for reaching out.

Could you provide additional information regarding the notice? Do you have an example or screenshot?

The more information, screenshot and examples you can provide the better the Community can assist!

Thanks!

Jess

Betreff: GDPR Consent - Log evidence

godaime — Tue, 12 May 2020 12:16:55 GMT

Hi Jess,

thanks for your reply. I try to add some screenshot and to add some information. This is the form I have on my webpage. I use a shortcode to insert it. As you can see, there are different links to my Privacy Policy, because I was trying to find a solution. I would expect to use only the second link, beside the second checkbox, whit the text "I agree to allow to store and process my personal data".

formIn the second image you can find the data collected when i submit the form. As you can see, all the data are collected correctly, and the legal basis for processing data is correctly set to "freely given consent".

But I should collect also the statement accepted, the phrase "I agree to allow...etc". I cannot find it. In the third image you can see the details of the properties, in particular about the legal consent.

Please let me know if you need further informations.

Thanks again!

Mary

Betreff: GDPR Consent - Log evidence

JessicaH — Tue, 12 May 2020 15:01:20 GMT

Hi @godaime,

Thanks for providing the screenshots.

I wanted to share this article with you as it provides more details about consent information (https://knowledge.hubspot.com/forms/add-notice-and-consent-information-to-your-hubspot-form-or-pop-up-form).

When a contact selects one of the checkboxes this information is stored in form of the subscription that is connected with the checkbox (see GIF).

The specific phrase is not stored in the contact record.

I hope this helps.

Take care!

Jess

Betreff: GDPR Consent - Log evidence

godaime — Tue, 12 May 2020 16:42:37 GMT

Hi Jess,

thanks for your reply. I understand that the phrase is not stored, so my problem is solved.

It's quite a strange behaviour, since the phrase is stored when I select a checkbox related to a submission (I can find a property Explanation with my phrase in subscription history).

I am not a lawyer, but I am trying to follow the GDPR guidelines from WP29 (such an headache)

https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=623051 (Page 20 Demonstrate consent)

I'm not sure that this aspect of Hubspot is fully compliant. Personally I think I will try to add the proof of consent inside the text of the message.

Again, thank you for your time.

Have a great day!

Mary