diff --git a/proposals/4265-dpo-role.md b/proposals/4265-dpo-role.md new file mode 100644 index 00000000000..9e8d5fddd77 --- /dev/null +++ b/proposals/4265-dpo-role.md @@ -0,0 +1,74 @@ +# MSC4265: Data Protection Officer contact in `/.well-known/matrix/support` + +[GDPR] Article 37 Nr. 1 requires data controllers and processors to designate a +Data Protection Officer (DPO). Furthermore, Article 37 Nr. 7 requires that the +DPO's contact details be publicised. This is most commonly done via the privacy +policy document. + +In Matrix, a homeserver's privacy policy is currently only made accessible via +APIs during [account registration]. This prevents clients from easily displaying +the contact information at later times and adds to the user's burden in finding +them. + +Additionally, homeservers themselves can have a similar need to get in touch +with another server's DPO, for instance to inform them about requests for +erasure as required by [GDPR] Article 17 Nr. 2. + +While a server's support document under [/.well-known/matrix/support] can expose +an "admin" contact, this might not be specific enough for the purposes outlined +above – especially since server administrators and data protection officers are +usually different roles in companies. + +The present proposal attempts to address these problems by exposing a dedicated +DPO contact in the server's support document. + +## Proposal + +A new role `m.role.dpo` is introduced for `Contact`s in +[/.well-known/matrix/support] + +``` json5 +{ + "contacts": [ + { + "email_address": "dpo@pizza.org", + "matrix_id": "@dpo:pizza.org", + "role": "m.role.dpo" + }, + ... + ], + "support_page": "https://www.pizza.org/support" +} +``` + +Servers are *not* required to provide an `m.role.dpo` contact. + +## Potential issues + +The DPO contact details being duplicated in two places introduces the +possibility that they get out of sync. Given that these contacts should rarely +change, this seems like a small problem, however. + +## Alternatives + +Rather than exposing the DPO's contact details, the support document could +publish the privacy policy URL, for instance via [MSC4266]. This could also be +considered an additional feature rather than a replacement, however. + +## Security considerations + +None. + +## Unstable prefix + +While this proposal is unstable, `m.role.dpo` should be referred to as +`org.matrix.msc4265.role.dpo`. + +## Dependencies + +None. + + [GDPR]: https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng + [account registration]: https://spec.matrix.org/v1.13/client-server-api/#terms-of-service-at-registration + [/.well-known/matrix/support]: https://spec.matrix.org/v1.13/client-server-api/#getwell-knownmatrixsupport + [MSC4266]: https://github.com/matrix-org/matrix-spec-proposals/pull/4266