Title: Data Processing Agreeent needed
Last modified: June 7, 2018

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# Data Processing Agreeent needed

 *  Resolved [klausharms](https://wordpress.org/support/users/klausharms/)
 * (@klausharms)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/)
 * Hi team,
 * we followed the discussion to the GDPR comliance of the All in one firewall, 
   which is generally fantastic stuff. But it is not useable in the EU because you
   need to set up a data processing agreement like Wordfence did already: [https://www.wordfence.com/gdpr/dpa.pdf](https://www.wordfence.com/gdpr/dpa.pdf)
 * So what do you think about this?
 * Thanks for supporting us.
 * Geetings
    Klaus

Viewing 5 replies - 1 through 5 (of 5 total)

 *  Plugin Contributor [wpsolutions](https://wordpress.org/support/users/wpsolutions/)
 * (@wpsolutions)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10377050)
 * Hi Klaus,
    Wordfence has a slightly different setup. They collect personal information
   such as email addresses from the people using their plugin, eg, cases such as
   activating their premium features etc. My understanding is that they would need
   to have a data processing agreement between WordFence (or the company owning 
   it) and the users of their plugin from whom they collect the personal data.
 * AIOWPS does not collect any information (personal or otherwise) from the website
   owners who use this plugin.
    Any data which is recorded as a result of this plugin
   is done by you for your own site and for your security purposes. Thus you can
   include your own disclaimer in your terms page to make this clear to people visiting
   the site.
 * (As far as I understand there are provisions in the GDPR for data collected for
   security purposes)
 *  [ognid](https://wordpress.org/support/users/ognid/)
 * (@ognid)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10429196)
 * > AIOWPS does not collect any information (personal or otherwise) **from the 
   > website owners** who use this plugin.
 * There would be a need for a data processing agreement if the developers were 
   controllers or processors (as defined by GDPR). If they only developed the plugin(
   the coding) and the plugin functions as a stand alone piece of software (eg. 
   does not send any data information to the development team and/or their data 
   servers, no screening by servers of the developers etc.), in that case I don’t
   see the need of an agreement.
 * To assess the need of an agreement I would appreciate if the team can answer 
   the following questions; Does the plugin sends data of my **website visitors**(
   eg. IP addresses, user-agent) to the servers of the developers?
 * Greetings,
 *  Plugin Contributor [wpsolutions](https://wordpress.org/support/users/wpsolutions/)
 * (@wpsolutions)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10429432)
 * Hi [@ognid](https://wordpress.org/support/users/ognid/),
 * > Does the plugin sends data of my website visitors (eg. IP addresses, user-agent)
   > to the servers of the developers?
 * No.
 *  [ognid](https://wordpress.org/support/users/ognid/)
 * (@ognid)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10429623)
 * Hi [@wpsolutions](https://wordpress.org/support/users/wpsolutions/),
 * Thank you for your quick response! You are an angel (and not a controller or 
   processor).
 * You have provided me the most compelling argument to **ditch Wordfence**, and
   to activate AIOWPS 🙂
 * I have checked the plugin for cookies, and the plugin does not set cookies for
   visitors either.
    So, as far as I know, your **plugin is “GDPR compliant” and
   GDPR does not apply to the developers** (no controllers/processors). You simply
   made available the code to ‘do it yourself’. Conclusion, no Data Processing Agreement
   needed.
 * GDPR does apply to website owners if they use the plugin (whitelisting, lock 
   out function), but as you mentioned before, GDPR allows controllers (eg. website
   owners) to process personal data for security reasons.
 * > (49) The processing of personal data to the extent strictly necessary and proportionate
   > for the purposes of ensuring network and information security, i.e. the ability
   > of a network or an information system to resist, at a given level of confidence,
   > accidental events or unlawful or malicious actions that compromise the availability,
   > authenticity, integrity and confidentiality of stored or transmitted personal
   > data, and the security of the related services offered by, or accessible via,
   > those networks and systems, by public authorities, by computer emergency response
   > teams (CERTs), computer security incident response teams (CSIRTs), by providers
   > of electronic communications networks and services and by providers of security
   > technologies and services, **constitutes a legitimate interest of the data 
   > controller concerned**. This could, for example, include preventing unauthorised
   > access to electronic communications networks and malicious code distribution
   > and stopping ‘denial of service’ attacks and damage to computer and electronic
   > communication systems.
 * Disclaimer: I am human and not error-proof. Therefore the text above can not 
   be seen as legal advice. But you get the picture 🙂
 * Have a nice weekend!
 * Greetings,
    Ognid
    -  This reply was modified 8 years, 2 months ago by [ognid](https://wordpress.org/support/users/ognid/).
      Reason: Addition of extra background information regarding GDPR
 *  [ognid](https://wordpress.org/support/users/ognid/)
 * (@ognid)
 * [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10429680)
 * Forget to edit this part:
 * > So, as far as I know, your plugin is “GDPR compliant” and GDPR does not apply
   > to the developers (no controllers/processors).

Viewing 5 replies - 1 through 5 (of 5 total)

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 * 5 replies
 * 3 participants
 * Last reply from: [ognid](https://wordpress.org/support/users/ognid/)
 * Last activity: [8 years, 2 months ago](https://wordpress.org/support/topic/data-processing-agreeent-needed/#post-10429680)
 * Status: resolved