Understanding Flamingo and GDPR: IP Storage, Data Export, and Compliance
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For WordPress site owners using the Flamingo plugin to store contact form submissions, navigating the complexities of data privacy regulations like the GDPR (General Data Protection Regulation) is a common challenge. A frequent point of confusion is how Flamingo handles personal data, such as IP addresses, and its integration with WordPress's built-in privacy tools.
The Core GDPR Questions Around Flamingo
Based on community discussions, the primary concerns are:
- IP Address Storage: Flamingo, by default, stores the submitter's IP address, which is considered personal data under GDPR.
- Data Export Functionality: Users want to know if data stored in Flamingo can be included in a personal data export for a user upon request.
- Automatic Data Deletion: Questions arise about automatically deleting old data to comply with data retention principles.
Official Stance and Built-in Features
The Flamingo team has implemented specific privacy features within the plugin:
- Personal Data Erasure: Flamingo is integrated with the WordPress personal data erasure tool (
wp_privacy_personal_data_erasers). This means you can erase all data related to a specific email address directly from the WordPress admin tools. - No Built-in Data Export: The developer's official position, as seen in the plugin's code and support threads, is that Flamingo does not support the personal data exporter (
wp_privacy_personal_data_exporters). The rationale is that the contact form submission data stored by Flamingo is typically not the type of data a user would want to "export" to another service, unlike social media data. - No Automatic Deletion: The plugin does not currently include a feature to automatically delete stored messages after a set period.
How to Anonymize IP Addresses in Flamingo
Since Flamingo often gets submission data from Contact Form 7 (CF7), the solution for IP anonymization involves filtering the data at the CF7 level before it is passed to Flamingo.
Solution: Add the following code to your theme's functions.php file or a site-specific functionality plugin:
add_filter( 'wpcf7_remote_ip_addr', 'wpcf7_anonymize_ip_addr' );
This filter hook utilizes a built-in CF7 function (wpcf7_anonymize_ip_addr) that anonymizes the last octet of an IPv4 address (e.g., 192.168.1.XXX) or the last 80 bits of an IPv6 address before it is sent to Flamingo for storage. This action is considered a sufficient step towards anonymization under many GDPR guidelines.
Important Considerations for Compliance
- Plugin Responsibility: It is crucial to understand that no plugin alone can make your website GDPR compliant. As repeatedly stated in support threads, the website owner is the "data controller" and is ultimately responsible for ensuring their site's compliance with laws like GDPR or HIPAA.
- Assess Your Needs: You must evaluate if storing full form submissions, including potentially sensitive data, is necessary for your business purposes. If it is, you are responsible for securing that data and handling user requests appropriately.
- Manual Solutions: For automatic data deletion, you may need to explore custom SQL queries or other WordPress management plugins to periodically clean out old Flamingo messages, as this functionality is not native to the plugin.
By understanding Flamingo's built-in capabilities and applying the necessary filters to anonymize data at the source, you can better align your use of the plugin with data privacy requirements. Always remember to review your specific legal obligations and seek professional advice if necessary.
Related Support Threads Support
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Prevent IP storinghttps://wordpress.org/support/topic/pevent-ip-storing/
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Personal data exporter/eraser compatibilityhttps://wordpress.org/support/topic/personal-data-exporter-eraser-compatibility/
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Add full year to date filterhttps://wordpress.org/support/topic/add-full-year-to-date-filter/
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Flamingo GDPRhttps://wordpress.org/support/topic/flamingo-gdpr/
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Exporting messages with Personal Data exporterhttps://wordpress.org/support/topic/exporting-messages-with-personal-data-exporter/
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HIPAA Compliancehttps://wordpress.org/support/topic/hipaa-compliance-3/
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GDPR Integrationhttps://wordpress.org/support/topic/gdpr-integration/
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GDRP and encryptionhttps://wordpress.org/support/topic/gdrp-and-encryption/
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I made a Simplified Chinese Translation for this pluginhttps://wordpress.org/support/topic/i-made-a-simplified-chinese-translation-for-this-plugin/
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Flamingo is not GDPR compliance with IPhttps://wordpress.org/support/topic/flamingo-is-not-gdpr-compliance-with-ip/
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Acceptance registration with Flamingo pluginhttps://wordpress.org/support/topic/acceptance-registration-with-flamingo-plugin/
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Plugin not compatible with WordPress GDPR export data feature.https://wordpress.org/support/topic/plugin-not-compatible-with-wordpress-gdpr-export-data-feature/
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Translation solutionhttps://wordpress.org/support/topic/translation-solution/
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Integration possibilities to Pipedrivehttps://wordpress.org/support/topic/integration-possibilities-to-pipedrive/
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GDPR data storage timehttps://wordpress.org/support/topic/gdpr-data-storage-time/