I’m sure many authors, and indeed any “page” owners, have recently received an email from Facebook saying that they are updating their Page Insights Addendum.
I was going to ignore it, but a friend of mine made me sit up and think when he said he would be closing down his FB presence as a result.
Time to investigate.
The addendum says FB, with no apparent way of stopping this happening short of shutting down your page, will be making each page admin a joint data controller, responsible under GDPR for the data processed on their page.
Now, the page admin has no access to individual personal data, and I quote from the update:
Page admins do not have access to the personal data processed as part of events but only to the aggregated Page Insights. Events used to create Page Insights do not store IP addresses, cookie IDs or any other identifiers associated with people or their devices aside from a FB user ID for people logged in to Facebook.
So, as an admin, I have access to zero personal data. Yet, I’m going to be made legally responsible and have to jump through a whole host of hoops just to keep talking to people… Because, the addendum goes on to state:
Where an interaction of people with your Page and the content associated with it triggers the creation of an event for Page Insights which includes personal data for whose processing you (and/or any third party for whom you are creating or administering the Page) determine the means and purposes of the processing jointly with Facebook Ireland Limited, you acknowledge and agree on your own behalf (and as agent for and on behalf of any such other third party) that this Page Insights Controller Addendum (“Page Insights Addendum”) applies…
Now, I’m not even sure what such a triggering-event could be! There then follows a lot of pretty confusing legalise, but the important bit to me is where it identifies the page admin’s role / responsibilities:
My reading of this is that every fan page / author page or indeed any page at all now needs a data protection policy, a data officer and a complaints / information response process for data subjects. That’s pretty onerous for most one-person bands!
Now, I’m not a lawyer and wouldn’t profess to know the answer. In a previous life, I would have had the budget to get this lengthy (and seemingly onerous) amendment interpreted. But, as a struggling author, I don’t have the resources to do this, or to manage it.
My question is, what are the options? I don’t seem to be able to turn off insights and so avoid the issue.
Does this mean the death of thousands, maybe millions of pages – or that authors and other page owners will simply run the risk of being prosecuted / sued?
Does anyone have any insight on this? Answers on a postcard, please…