XEP-xxxx: Best practices for GDPR compliant deployment of XMPP

Abstract:This informational XEP provides information on deploying XMPP in way that is compliant with the General Data Protection Regulation (GDPR) of the European Union.
Author:Winfried Tilanus
Copyright:© 1999 – 2017 XMPP Standards Foundation. SEE LEGAL NOTICES.
Status:ProtoXEP
Type:Informational
Version:0.0.1
Last Updated:2018-05-22

WARNING: This document has not yet been accepted for consideration or approved in any official manner by the XMPP Standards Foundation, and this document is not yet an XMPP Extension Protocol (XEP). If this document is accepted as a XEP by the XMPP Council, it will be published at <http://xmpp.org/extensions/> and announced on the <standards@xmpp.org> mailing list.


Table of Contents


1. Introduction
2. Requirements
3. Glossary
4. XEPs covered in this document
5. Step 1: Is the GDPR appliccable to you?
6. Step 2: Make sure your processing is according to the GDPR
    6.1. Check logging and log rotation
    6.2. Check your spam filtering
    6.3. Check your MAM and offline storage settings
7. Inform your users
    7.1. Create a privacy statement
    7.2. Publish your privacy statement
8. Security Considerations
9. IANA Considerations
10. XMPP Registrar Considerations

Appendices
    A: Document Information
    B: Author Information
    C: Legal Notices
    D: Relation to XMPP
    E: Discussion Venue
    F: Requirements Conformance
    G: Notes
    H: Revision History


1. Introduction

The General Data Protection Regulation (GDPR) is an European Union wide regulation about handling personal data. This XEP is a central place with information for server operators who need (or want) to have their server GDPR compliant. This information is general and still subject to debate amongst lawyers, it doesn't offer a legal advice. When in doubt consult your own lawyer.

These best practices are aimed at operators of public jabbers servers that are federating with other public jabber servers. Though this XEP is written with a typical server setup in mind, it contains also some considerations for other setups. This XEP does not fully cover the requirements for private XMPP deployments, like an in company server and this XEP does not cover situations where the XMPP traffic is used to observe and analyse the behaviour of users.

The XMPP core specifications and many of the XMPP Extension Protocols describe handling of data that is regulated by the GDRP. But XMPP is deployed in many different jurisdictions and the aim of the protocols is to ensure interoperability, not to encode (local) laws into the protocols. So the protocols will only contain general information on the data that processed and will offer general functionality that is not specific for one jurisdiction. This XEP is the central point for gathering all information regarding setting up a server that is compliant with the GDPR. This XEP is accompanied by several other documents, including a template for Terms of Service and a template for a Privacy Statement.

2. Requirements

The aim of this XEP is to make it easy for operators of public XMPP servers to setup a GDPR compliant server. This XEP does not cover private setups or setups where the processed data is used for any purpose other then the communication between the end users.

3. Glossary

TBD

4. XEPs covered in this document

Table 1:

XEPRelevance

5. Step 1: Is the GDPR appliccable to you?

TBD

6. Step 2: Make sure your processing is according to the GDPR

6.1 Check logging and log rotation

TBD

6.2 Check your spam filtering

TBD

6.3 Check your MAM and offline storage settings

TBD

7. Inform your users

7.1 Create a privacy statement

TBD

7.2 Publish your privacy statement

TBD

8. Security Considerations

REQUIRED.

9. IANA Considerations

REQUIRED.

10. XMPP Registrar Considerations

REQUIRED.


Appendices


Appendix A: Document Information

Series: XEP
Number: xxxx
Publisher: XMPP Standards Foundation
Status: ProtoXEP
Type: Informational
Version: 0.0.1
Last Updated: 2018-05-22
Approving Body: XMPP Council
Dependencies: XMPP Core, XEP-0001
Supersedes: None
Superseded By: None
Short Name: NOT_YET_ASSIGNED
This document in other formats: XML  PDF


Appendix B: Author Information

Winfried Tilanus

Email: winfried@tilanus.com
JabberID: winfried@tilanus.com


Appendix C: Legal Notices

Copyright

This XMPP Extension Protocol is copyright © 1999 – 2018 by the XMPP Standards Foundation (XSF).

Permissions

Permission is hereby granted, free of charge, to any person obtaining a copy of this specification (the "Specification"), to make use of the Specification without restriction, including without limitation the rights to implement the Specification in a software program, deploy the Specification in a network service, and copy, modify, merge, publish, translate, distribute, sublicense, or sell copies of the Specification, and to permit persons to whom the Specification is furnished to do so, subject to the condition that the foregoing copyright notice and this permission notice shall be included in all copies or substantial portions of the Specification. Unless separate permission is granted, modified works that are redistributed shall not contain misleading information regarding the authors, title, number, or publisher of the Specification, and shall not claim endorsement of the modified works by the authors, any organization or project to which the authors belong, or the XMPP Standards Foundation.

Disclaimer of Warranty

## NOTE WELL: This Specification is provided on an "AS IS" BASIS, WITHOUT WARRANTIES OR CONDITIONS OF ANY KIND, express or implied, including, without limitation, any warranties or conditions of TITLE, NON-INFRINGEMENT, MERCHANTABILITY, or FITNESS FOR A PARTICULAR PURPOSE. ##

Limitation of Liability

In no event and under no legal theory, whether in tort (including negligence), contract, or otherwise, unless required by applicable law (such as deliberate and grossly negligent acts) or agreed to in writing, shall the XMPP Standards Foundation or any author of this Specification be liable for damages, including any direct, indirect, special, incidental, or consequential damages of any character arising from, out of, or in connection with the Specification or the implementation, deployment, or other use of the Specification (including but not limited to damages for loss of goodwill, work stoppage, computer failure or malfunction, or any and all other commercial damages or losses), even if the XMPP Standards Foundation or such author has been advised of the possibility of such damages.

IPR Conformance

This XMPP Extension Protocol has been contributed in full conformance with the XSF's Intellectual Property Rights Policy (a copy of which can be found at <https://xmpp.org/about/xsf/ipr-policy> or obtained by writing to XMPP Standards Foundation, P.O. Box 787, Parker, CO 80134 USA).

Appendix D: Relation to XMPP

The Extensible Messaging and Presence Protocol (XMPP) is defined in the XMPP Core (RFC 6120) and XMPP IM (RFC 6121) specifications contributed by the XMPP Standards Foundation to the Internet Standards Process, which is managed by the Internet Engineering Task Force in accordance with RFC 2026. Any protocol defined in this document has been developed outside the Internet Standards Process and is to be understood as an extension to XMPP rather than as an evolution, development, or modification of XMPP itself.


Appendix E: Discussion Venue

The primary venue for discussion of XMPP Extension Protocols is the <standards@xmpp.org> discussion list.

Discussion on other xmpp.org discussion lists might also be appropriate; see <http://xmpp.org/about/discuss.shtml> for a complete list.

Errata can be sent to <editor@xmpp.org>.


Appendix F: Requirements Conformance

The following requirements keywords as used in this document are to be interpreted as described in RFC 2119: "MUST", "SHALL", "REQUIRED"; "MUST NOT", "SHALL NOT"; "SHOULD", "RECOMMENDED"; "SHOULD NOT", "NOT RECOMMENDED"; "MAY", "OPTIONAL".


Appendix G: Notes


Appendix H: Revision History

Note: Older versions of this specification might be available at http://xmpp.org/extensions/attic/

Version 0.0.1 (2018-05-22)

First draft.

(wt)

END