Hello everyone, it is currently 13h00 and I am ready to start the conference that I had planned for today, which is called How to configure Matomo in the respect of the RGPD.
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Before starting, I just want to make sure that the sound is ok. Frédéric, do you hear me correctly?
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Yes, perfectly.
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I am going to start this conference, which is scheduled from 13h00 to 13h45, including the different questions and answers that each of you may have in relation to this issue.
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Do not hesitate to go to chat.matomocamp.org to register if you have not already done so, and once there, do not hesitate to ask questions in the room that is scheduled for this event.
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Frédéric, who is the moderator of this conference, will ask these questions, either directly or at the end of the conference.
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You can also ask questions throughout the MatomoCamp on this particular issue, whether today or tomorrow, since the Q&A room remains open.
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I will perhaps, for the needs of the conference, keep a little more of a passing band and stop my camera.
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The idea in this conference is first that I introduce myself, then that I present to you the objectives of this conference,
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then to give you a definition of what the audience analysis is, since in a way it is what we are talking about today within the framework of the RGPD.
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Then I will go over a definition of what personal data is in the sense of the RGPD.
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Then I will deal with the exemption of consent with Matomo, which concerns the majority of the cases for which people will use Matomo and how to do that in respect of the RGPD.
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Then I will address a part that we see quite few.
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How do we do when we want to deal with personal data with Matomo and that we must recover the consent of the user?
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And I will conclude this conference.
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To introduce myself quickly, my name is Ronan Chardonneau.
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I was lucky and honored to work for the Matomo team.
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When we say the Matomo team, it means a lot of things.
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I mainly worked for Inocraft from 2017 to 2019, which is the private company that is the main contributor to the development of Matomo.
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In fact, it is not exactly true that I worked for the Matomo team, I worked for the Inocraft team.
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But the Inocraft team being the main contributor to the Matomo project, in a way, through my work that I was able to do within the Inocraft company,
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I was able to contribute to the development of the Matomo software and the Matomo software, in a way, I contributed a lot as a volunteer,
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especially through the dissemination of knowledge, of tutorials that you can find on the Internet,
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either on my Pertube channel, either on my YouTube channel, or also on different MOOCs that I was able to create,
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including that of the Floss Marketing School, or also a MOOC that I was able to create on the Zest platform of knowledge, which is an association for non-profit purposes,
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which releases tutorials, knowledge around different technologies or other knowledge.
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What is interesting is that when I worked for Inocraft, from 2017 to 2019,
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I was the person who was in charge of the implementation of the RGPD within the company.
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And that allowed me to see a lot of things.
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And the idea is, through this conference, and also the experience that I was able to have after leaving Inocraft,
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to be able to share a little bit of all this in today's conference.
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I am a trainee and independent consultant on Matomo, formerly it was not Matomo, it was called P-Week.
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Since 2010, I have been one of the very first people to have a certain way to bet on P-Week, on Matomo,
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and to have decided to build a whole structure, a whole business around that,
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which is in particular the subject of a conference that will take place just after, from 2pm to 3pm, which I will do in English,
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where I will explain how to develop an economic activity around Matomo.
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This is my main job, I have been a trainee and independent consultant on Matomo since 2010,
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and I am also the head of social and e-danger conferences that I have been in digital marketing,
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now we call it digital marketing, since 2012.
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In fact, I am training students in digital marketing, and for the past few years now,
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I have been trying to bring them knowledge in digital marketing using free software,
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and Matomo is naturally the one I am going to talk about the most.
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I have a third activity that is quite recent, which is that I am an international expert on the subject of free software
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from the Ministry of Higher Education, Research and Innovation,
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on the subject of open science.
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It consists of going abroad and being the spokesperson, the ambassador of the government
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to explain what the government's policy is in terms of open science,
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and in particular what is the policy that is carried out by the government
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around the release of software produced by researchers
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that in a certain way must be in free access and under license.
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So this is a project that is brand new for me,
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I may have the opportunity to talk about it in other conferences later.
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And I am also the creator of a platform called Flossmarketingschool.com
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that I strongly advise you to go and consult,
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it is an internet site on which I actually release all the courses that I provide at e-danger,
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these are courses in free access, you have tutorials,
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textual explanations, you also have exercises,
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and it's really great if you want to educate yourself in free software and digital marketing.
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So the objective of the conference will be the following,
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is that you discover how to learn how to get in concrete conformity with Matomo for the RGPD,
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so I will share my screen, I will show you the different contents,
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I will show you the back-end of Matomo,
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what are the options through which you have to navigate to be in conformity.
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If you have any questions, feel free to go to chat.matomocamp.org
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and ask your questions, since it is through this intermediary that I will be able to help you even more,
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to be closer to your needs.
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So I will now advance a little, I will come back to this link a little later,
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which is actually the key to the conference,
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it is a guide that LACNIL has put online and which explains why in a certain way
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and how software editors can be exempt from consent,
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so it will be very interesting since it is a list of factors that are indicated
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that explains how a software editor can be exempt from consent
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and how we can collect data on users directly
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without having offered them an acceptance list.
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So the prerequisites for following this conference are the following.
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I consider that for this conference, most of you already know the RGPD,
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so if this is not the case, I strongly encourage you to go to the official link,
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eur-lex.europa.eu,
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on which you will find the official text of the RGPD which is 88 pages long.
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Its reading and comprehension, to have it done,
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require half a day of work or at least time to reflect, to read.
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It is worth the investment in time, since it also allows you to be well educated,
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well trained, what is the RGPD.
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One of the basic rules of the RGPD is that the text must be readable and understandable to all,
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so we are not on a document that needs to be BAC plus 15 to be able to read it.
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And it's really very interesting because it allows you to see everything in the RGPD,
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although not everything is concerned with everything that the RGPD says,
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but it allows you to know what the RGPD is by a source of information
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that has not been interpreted by a third that comes directly from the EU.
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And that has its advantage.
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Then I strongly recommend you to follow MOOCs that are related to the RGPD application or the RGPD in general.
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Unfortunately, the MOOC edited by Acneel is currently in the process of reissue,
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so if you go to it, it's a shame because the old version was very well done,
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I think it could have gone online.
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You will find it on this link because there is one day or the other where they will update it,
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but it is good to know that they are in the process of renovation.
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However, I know that when I started to educate myself on the RGPD,
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Acneel had not yet released its online MOOC.
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I had followed a training course by a Dutch university
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which also apparently reviewed its MOOC.
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It seems to me that it was this one, but I'm not sure.
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I put the link there as an indicator.
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I think you can easily type MOOC RGPD on a very well-known research engine
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and easily find other MOOCs,
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but I assume that to follow this conference,
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you already know what a MINIMA is than the RGPD.
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Before directly attacking the conformity of Matomo in the RGPD framework,
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let's go back to the fundamentals and basically explain what we are talking about.
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We are talking about Matomo.
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What is Matomo? It is a solution in audience analysis.
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The big question is what is a solution in audience analysis?
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A solution in audience analysis is nothing more or less than a system of information.
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It is just a database.
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You have to understand what Matomo is.
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It is a database.
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It is a place that stores data.
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What does it contain?
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It contains traces of exchange between two computers,
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between the computer that will be the client,
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that is to say the visitor or the user,
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if you have a mobile application, if you have an internet.
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Taking a website is perhaps much simpler.
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You have a visitor who arrives on your website.
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Your website is hosted on what?
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It is hosted on what is called a server.
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You have a request that is made by a computer, that is to say a client,
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and you have in front of you another computer that responds to it, which is called the server.
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These two entities communicate via what?
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They communicate via what we call HTTP requests.
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What do these HTTP requests contain?
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They contain information that is standard in communications between two computers,
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which are the IP address of the client computer,
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the time and date at which the request is made,
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the page that is requested,
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so the page that is requested is also a URL,
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and via the URL the title of the page is also recovered.
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The way in which the user came to the site,
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how he or she knew it in a certain way,
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which is called the URL reference,
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is also transmitted behind everything that is going to be screen resolution.
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Also through what is called the user agent,
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the language of the browser is also transmitted.
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And behind a little more information on the browser,
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such as its version or the operating system on which it is used.
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All this to tell you that this information is stored in a database.
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I will maybe share my screen, it may be more explicit directly,
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and that's why I think that Matomo is pretty great.
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At least at Matomo you see what the database looks like.
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Frédéric, do you see my screen well, what I share?
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Yes, absolutely.
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Typically, this is the database of Matomo.
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This is what you have to install the day you install Matomo on the server of your choice.
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We must not forget that Matomo, what makes it strong,
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compared to all the other software on the market,
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is that it is a free software.
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It is a software that you directly recover on a site,
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namely matomo.org.
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Then, once you have this software,
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you decide on the server on which you are going to install it.
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And when you install it on a server,
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you have to install what is called a database and it is there, our database.
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This is where you have these famous HTTP requests
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which contain data that have been extracted
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and which have then been inserted into the database.
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This is where we see, for example, the identifier of the visit,
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the site on which you deployed Matomo.
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You will then have everything that will be the IP address of the user.
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You will have the location that will be represented here.
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The information that we see here is not necessarily the most explicit,
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but if we go a little more to the right,
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we have directly information that we are more used to seeing,
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namely the reference, namely the language of the navigator,
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namely what type of engine is used,
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basically which navigator, the version of the navigator, etc.
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In the end, everything is recorded here in this famous database.
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A solution for audience analysis, I remind you,
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is just a database that contains the basic information
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that has exchanges between a navigator, a client computer, and a server.
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To make it simple, what are the personal data collected by default in Matomo?
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In reality, in these famous personal data that we have, we don't have much.
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Probably the most intrusive that we can have is the famous IP address
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which also allows us to identify generally a home,
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since the IP address is provided by your Internet access provider.
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But in reality, it is especially dangerous if within a database,
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you only have one person, since in this case,
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it would mean that this IP address, at least one person,
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your Internet access provider can know who is behind,
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which is naturally less the case when in a database you have more individuals.
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All this to tell you that already, in Matomo,
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you don't have any information that is very personal.
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Now, however, what you need to know is that in Matomo,
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you can extend its data collection power with specific monitoring codes,
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which are the object of a documentation found on developer.matomo.org,
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which is represented by, for example, personalized dimensions,
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which will be information, data that you can assign to your visitors,
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which allows you to know more about them.
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These data do not come from the Holy Spirit, naturally,
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they come because they are already probably present on your website.
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For example, you have an e-commerce site,
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and on your e-commerce site, a person, when creating an account,
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will indicate, for example, his name and first name.
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This information is stored in the database linked to your website,
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and you can, through personalized dimensions,
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come and collect, for example, this data,
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and match it with the visit.
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But this will really be an action that will be done by the website editor,
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the person who controls it on the source code,
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and who will decide, of his own free will, to be able to put this personal data.
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Same thing with the user ID.
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This is the same.
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This is a code that specifically allows you to recognize the user.
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But this is the same.
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You can recognize the user only if he or she has given you the information.
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This will typically be the case when a person is going to log in on a site.
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I take for example the example of an e-commerce site.
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If a person logs in on an e-commerce site,
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it is that at some point, he or she will decide to create an account on your platform,
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and when the person creates an account,
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she will give you, or in any case you,
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you will make a kind of system to be able to put an ID.
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Generally, the ID will be the nickname,
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that the person will have decided to create when he or she has created the account,
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which will be used to create the user ID.
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After that, this is more of a point of surveillance.
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Be careful because the way you integrate the code into Matomo
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can be done through plugins.
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This is especially the case when you use, for example,
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plugins already developed for WordPress to integrate Matomo,
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or PrestaShop, or whatever you want.
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In fact, these plugins, you have to imagine that you have integration teams,
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you have developers who create specific features
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that are often very requested for these CMS,
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and which can automatically include the collection of personal data.
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You can imagine, typically, the case of e-commerce.
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You develop a store on PrestaShop,
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or you develop a store on WordPress.
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Naturally, if you put Matomo,
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you are waiting for Matomo to collect information
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about e-commerce, shopping cart, etc.
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By using these plugins,
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it is not said that by default,
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these plugins do not directly integrate the functions of this e-commerce,
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which can be considered,
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in any case, this is the case, we will come back to it later,
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by LACNIL as being intrusive data,
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in any case, which requires the user's prior agreement to be able to collect,
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since naturally, through an electronic transaction,
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we can indirectly know who is the person who is hiding behind the command.
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And then, naturally, in Matomo,
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we can find personal data that comes up when your site is poorly designed.
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We can imagine, for example, a website for which you have URLs,
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and the URLs in question contain the name and first name of an individual,
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or an identifier, something like that.
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This is especially the case on certain sites,
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when you connect to a back-office,
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sometimes the developers had the bad idea of putting the user's identifier in the URL,
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and when this is the case, naturally, when this URL is loaded,
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it sends the information directly to Matomo.
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But by default, normally, in Matomo,
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the most intrusive information that you are going to get,
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it will be the IP address.
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All this to say that by default,
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there is not much you should be afraid of
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to be in compliance with the RGPD,
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even if we will see it just after,
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there are still a few little things that will have to be done.
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On the other hand, where you should be well concerned with this RGPD problem,
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this is all the diapo that I have just gone through.
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Naturally, if you have specific codes,
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there you get personal data,
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and there you risk much more my opinion of the law,
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if there are things that are...
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My data is controlled by you.
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So, to remember that it is very important,
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in France, the RGPD application is done via the ACNIL authority.
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This is not a small information,
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that is to say that I made the choice today to do this conference in French,
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simply because for me it is quite simple
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to be able to verify the ACNIL doc and present it to you.
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However, what I am telling you here for France,
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it does not work naturally if you have a website
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that is for a country abroad,
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since when it comes to abroad,
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there is no longer the ACNIL that is cold,
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so you have to look at each time
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which is the equivalent of the private life commission
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in the country you are aiming for.
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We can imagine a French company
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that develops a site for Germany,
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there it goes that it is not the ACNIL rule
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that will have to be followed to put Matomo in conformity,