John Phillips
pfm Member
The 'if you don't like it, don't join' is, per se, perfectly OK under GDPR (I am not a lawyer but I have worked with lawyers on GDPR issues, and on drafting ISO standards for auditing privacy compliance).Just a caveat to all this, based on my comments upthread. The privacy policy of the Proboards forum is pants, and grants all sorts of rights to exploit users' personal information, with no way to decline it. It's basically 'if you don't like it, don't join'.
You do have to be given the means to make that a meaningful and informed choice. The policy does provide me with some concerns, but it's one of the shorter, clearer and simpler policies I have read. Processing personal data necessary for providing the service is essential if you do sign up and the policy seems largely clear. The management of personal data processing by third party controllers and how the data subject can exercise his/her rights may need some improvement but this might be addressed by appropriate practice consistent with the policy.
There are some over-expectations regarding data subject rights under GDPR. There are some improvements. In, for example, the definition of what is personal data and the provision and withdrawal of consent. But the GDPR's major impact will be in compliance and enforcement.
The GDPR's provisions fall upon whoever collects and processes personal data. ProBoards certainly falls into that category, and there are new enforcement mechanisms that may be useful when there are problems. However, I can imagine a system where whoever sets up a board does not himself/herself collect and process personal data, or perhaps does so to a very limited extent such as managing membership. There will have to be a few precautions there but I am not sure it will be quite as bad as you suggest. Given the recent fuss about Facebook, this should give people pause. It's also not going to meet the minimum requirements under GDPR, and when it doesn't, it's not Proboards who will be liable, it's the 'owner' of the forum.