Data Protection Issues

Submitted by Theresia Rasche on Mon, 05/30/2022 - 08:47
Forums: 
General discussion

Der all,

we are currently in the process of implementing H5P into our moodle at our university.

According to this website, some personal data (like IP adresses) is transferred to H5P for statistical reasons.Transferring data means two things:

(1) We'd have to sign an DPA (Data Processing Agreement) - does H5P provide our university with a DPA?

(2) We might need to meet the conditions acc. to Art. 44 GDPR. Where are the servers located that process/store the personal data?

According to sec 1.5 of the terms of use, H5P will store data on Amazon Web Service (AWS) Servers. Is the data for statistical usage also stored on AWS-Servers? If yes, we'd have to encounter the whole issue of transferring data to the US. If not - where are the servers of H5P located?

Thanks a lot in advance for your answers.

Theresia

otacke's picture

otacke

Tue, 05/31/2022 - 00:20

Hi  Theresia!

(1) I am not a lawyer, but a) storing the IP address of the server that serves your H5P contents is hardly personal data (server IP address !== any user's IP address) and b) that data is only transferred if you have checked the respective plugin option to share statistical data in the first place.

(2) Wherever your server is and your users leave tracks on your server - because the statistical data does not contain personal data if it is transferred at all.

From what I know about H5P, the section that you're citing is related to the H5P OER Hub only. That's where your users can share their content if you have activated the H5P OER Hub and if they decide to. That's what AWS is used for. Where the statistical data - again, not personal data - is stored, that I don't know and someone from the H5P core team would need to answer.

Best,
Oliver

falcon's picture

falcon

Wed, 06/01/2022 - 21:51

Hi Theresia,

What Oliver says is correct. The statistical data is stored on Digital Ocean servers. They are also US owned, but there isn't any personal information in those statistics and they may be toggled on or off.