GDPR consent and personal data management

Consent & Personal Data Mgmt

Aptilo GDPR compliant consent and personal data management solution

CONSENT & PERSONAL DATA MANAGEMENT MATTER

A Wi-Fi service is an excellent platform for hypertargeted marketing. Our customers have been asking for tools to get end-users’ consent to use their personal data for marketing. They also want to give end-users transparent access to that personal information. In some markets such as Europe, with the General Data Protection Regulation (GDPR), it’s required by law. In all markets, it makes common business sense.

Are you using a central consent and personal data management system for all your different services including Wi-Fi? Or, are you looking for an end-to-end solution just for your Wi-Fi service? Either way, Aptilo’s flexible platform will deliver what you need.

With us, you can even minimize the load on your customer service organization. Use the Aptilo SMP Privacy Self-Management™ module to let end-users manage their own consent and personal data.

DEPLOYMENT SCENARIOS

How much of the Aptilo consent & personal data management features do you need? It depends on who you are. A large operator with many different services may want to have their own central system. A conference center may want to have an integrated end-to-end solution for their Wi-Fi service. Below we will show the three most common deployment scenarios.

The base in all scenarios is the Aptilo Service Management Platform™ (SMP) with inherent functionality for personal data protection:

  • Configurable time that personal raw data are saved (we recommend max 30 days)
  • Aggregate and thus anonymize session data for analytics (configurable time)
  • Centralized log function with support for external syslog
  • Audit log – who has done what in the system
  • Automatic purge of accounts after expiration
  • Separation of account information from system information in backups
  • Support for export of personal data

PRIVACY SELF-MANAGEMENT

If saving operational costs is a priority, you most likely want this. It does not get more efficient than our full concept with privacy self-management. The end-users can handle their consent and personal data, so your employees don’t have to.

Everything including captive portals with their consent pop-ups, integrated into one nice package.

How users can access privacy self-management

How do users get access to handle their consent and personal data? It’s up to you. We offer a host of options.

  • Captive Portal

  • E-mail after login

  • SMS after login

  • Sent from customer care

  • Your website

HANDLED BY CUSTOMER CARE

Aptilo consent personal data management handled by customer care

Do you want to save on the Aptilo privacy self-management option? Do you have other reasons your customer care should handle the process? Then this deployment scenario is for you. Your customer care organization handles all requests from users. They administrate users’ consents and personal data. You must identify end-users when they contact customer care. Send a pin code to them via a verified e-mail or SMS address.

Make it as automatic as possible

Some legislations, such as European GDPR, require you to erase all personal data upon request from the end-user. You must do so within 30 days (GDPR).

If you have to let your customer care handle this, we recommend that you use an automatic feature in Aptilo SMP. Configure it to, after 30 days for GDPR, aggregate all personal data and erase it in logs. You will still reap the benefits of aggregated and anonymized analytics. But, there will be no trace of personal data left after the 30 days.

You may also set user accounts to purge after 30 days. This way your customer service organization does not even have to delete the account. They can just say, “We will erase all your personal data within 30 days.”

The best option of all is to use our privacy self-management features. Many users would love to let you keep their data, just as long as you send them relevant information and offers.

APTILO AS AN ADJUNCT SOLUTION

Aptilo consent and personal data management as adjunct solution

Do you like what you see above, but can’t switch to Aptilo SMP? (At least not right now). This scenario is for you. The Aptilo consent and personal data management features as an adjunct GDPR compliant solution to your existing system (third-party Wi-Fi Service Management System or AAA server).

Integrate the Aptilo consent management with your existing system through our REST API. The Aptilo personal data management, including the privacy self-management features, can be easily integrated if you can adapt to our REST API. If not, we will need to make a custom integration for the personal data management part.

USING THIRD-PARTY SYSTEM

Using third party consent personal data management

In this scenario, you have a central third-party system to handle consent and personal data for all your services, not just for your Wi-Fi service. The Aptilo SMP is still there with all the inherent functionalities for personal data protection. The third-party system interacts with personal data from Aptilo SMP via REST API. In this scenario, we have also assumed that a third-party captive portal is used, as it needs to be tightly integrated with the third-party consent and personal data system. It is possible to instead use the Aptilo SMP Captive Portal, but the same integration is then required as a professional service.

WHAT IS GDPR?

  • Harmonize laws in EU

  • Overrides local laws

  • In effect since 2016

  • Fines start May 2018

The General Data Protection Regulation (GDPR) is intended to strengthen data privacy for all individuals within the European Union (EU). It has been in place since 2016 ([EU] 2016/679). What’s new is that EU will enforce this law with heavy fines starting May 25, 2018.

The fines for a business can be 4% of worldwide sales up to 20 MEUR. The GDPR overrides any local data privacy laws within Europe. Anyone that is collecting and/or processing any personal data within the European Union must comply with GDPR.

Many countries around the world have similar laws and those without legislation will be inspired by the European GDPR.

RIGHTS OF THE INDIVIDUAL

  • Give consent

  • View my data

  • Correct my data

  • Export my data

  • Be forgotten

GDPR gives individuals more control over their personal data provided to companies operating in the European Union (EU), wherever they are based.

As a provider of Wi-Fi services, you must get users’ explicit consent on exactly how you will use their personal data. Upon request, you must also give any user transparent access to view and correct their personal data. One of the most important rights is the right to be forgotten. Upon request, you must delete all personal data, including the ones you may have in backups. You must also be able to provide users with their personal data exported in a machine-readable format.

You must execute these user requests within 30 days. However, Aptilo has taken the stand that you are better off as a business if you can give your users transparent and immediate access. This is why we have built the consent and personal data management features described in the other sections on this page.

PERSONAL DATA

All data that directly or indirectly can be tied to a person is personal data. Obvious data like name, address, e-mail and phone number, but also less obvious data. The graphic below includes some examples.

Personal data according to GDPR

GDPR AND USER CONSENT

  • Explicit consent

  • Detailed consent

  • Easy to understand

  • access type specific

GDPR is clear about consent. An individual must understand exactly what he/she has consented to for how their personal data will be used. Gone are the days when the personal data consent was buried in a “General Terms” link. A link which few users would click on anyway.

With GDPR, users must give explicit consent to everything concerning their personal data. And, it can’t be “lawyer-speak”. It must be written in a way that’s easy to understand.

All this means that the required consents will differ depending on the access method used. For instance, a Facebook login may require a specific consent for marketing. This consent allow you to send marketing information to the user, tailored to their public Facebook profile (age group and gender etc.). This is why we have built a flexible and comprehensive consent management tool. Learn more about it in the consent management section on this page.

Aptilo SMP Management of user consent

FLEXIBLE CONSENT MANAGEMENT

  • Consent with terms

  • mandatory or optional

  • Shown dynamically

  • Multilingual support

  • Revision handling

The consent management features allow you to flexibly handle users’ consent how you will process their personal data. They are built to support legalizations such as the European GDPR. Each consent is defined with a detailed terms text. Aptilo’s solution is also coupled to one or many access methods, such as Facebook login or click-and-connect. This means that the correct consent will always dynamically show up in the Aptilo SMP captive portal. The consent text can be multilingual where the correct language is used based on the browser language.

It is easy to handle a user’s consent over time with the Aptilo SMP consent management features. Revision handling of changed consent improves traceability over time. The tight integration with the Aptilo captive portal makes the task of collecting a user’s consent a breeze. With the Aptilo SMP Privacy Self-Management™, you can even leave it to the end-user to handle their own consents.

SMART CONSENT POP-UP

Aptilo SMP smart consent pop-up

The consent user interface is designed as a pop-up (safe from pop-up blockers of course) separated from the captive portal design. This serves three purposes. The detailed consent information is not visible from the start,  which improves the sign-up rate as the users will not be discouraged from using the service. The important consent information is also more likely to be read by the user if it is clean and consistent in design. Furthermore, it allows you to add new consents and update existing consent texts without making any changes to the portal.

As discussed above, all consents coupled with the access method the user is using will automatically show up in the pop-up. The user can fold down the detailed term for a consent with a simple click.

You can define consents as mandatory. The “save” button will only be available, and the Wi-Fi service accessible, if the user makes an active choice to all mandatory consents.

Some legislation such as GDPR requires verification of the user’s identity (double opt-in). This is handled by the portal design and flow which will send an SMS or e-mail to the user with a link and a verification code. To gain access, the user either clicks on that link or enters the verification code at the portal.

ACTIONS THAT TRIGGER NEW CONSENT

The Aptilo smart consent pop-up will be triggered also for existing users under certain circumstances.

User selects a new access method

Let’s look at a common scenario. The user starts with a 30-min free anonymous click-and-connect service and agrees to the general terms & conditions. After this, he/she might use the Facebook login to get another 4 hours of access. This will trigger a consent pop-up with the new consent for Facebook login highlighted.

When terms for a consent have changed

It’s likely that the terms text for a specific consent, for instance how e-mail information will be used, will change over time. Here the system will trigger a pop-up the next time the user connects to the service, highlighting both the old and the new updated terms text. The pop-up will not be triggered if the system administrator marks the update as minor, such as correcting a misspelled word.

Management of personal data and consent for compliance with legislation such as GDPR

PERSONAL DATA MANAGEMENT

With the Aptilo personal data management, you can handle users’ personal data including the consent they have given for use of the data. With this tool you can view, correct, export and delete personal data. You can also handle the associated consents. This allows you to offer a Wi-Fi service compliant with legislations such as the GDPR. It provides total transparency as to what data you have stored about the user and how it will be used. It also supports the “forget me” action, erasing all information about the user.

Handled by customer care

Your customer care organization can handle a user’s request over the phone to administrate their personal data and consents. For security reasons, your customer care must identify the user through a pin code. The pin code is sent to a verified e-mail address or mobile phone (SMS).

Privacy self-management

A more cost-effective method is to allow the user to handle their own personal data and consent through the Aptilo Privacy Self-Management™ module. The user will log-in to the self-care web portal using the same access method they used to access your Wi-Fi service.