Bringing GDPR Protection to WordPress with Scott DeLuzio

Intro: Hello everyone and welcome to episode 83 of How I Built It. In today’s episode I talk to Scott DeLuzio about one of this summer’s hottest topics: GDPR. Scott and I spoke about this just days before the regulation took hold, so we were working through what it is, how it affects us, and of-course how his plugin can help. I should remind you that we are not lawyers, and if you have serious GDPR concerns, you should talk to your lawyer! But if you’re curious about some good tools, this is a great episode!

This episode is brought to you by Pantheon and MailPoet, who you’ll here about a little later. But for now, on with the show!

Joe Casabona: Hey, everybody. Welcome to another episode of How I Built, the podcast that asks, “How did you build that?”

Today my guest is Scott DeLuzio. And Scott, I’m going to let you introduce yourself because I know you have a few different things, and you’ve been associated with the show before. So first of all, Scott, thanks for joining me today. I appreciate it.

Scott DeLuzio: Yeah, sure. Thanks for having me, my name is Scott DeLuzio. I started developing plugins for WordPress really as a way to scratch my own itch. I’ve been listening to this show for a while, and I know that I’m not quite alone there I know that a lot of other people have done that, but in doing that I got pretty good at solving problems. When I’d be at work camps or meet ups and things like that, talking to people about the problems they were having, I’d sort of think of ways to solve their problems. Or realize, “Yeah, that’s something I’ve had a problem with too.

And so I’d start to come up with ways to solve their problems in addition to my own problems. Over the last few years I’ve developed 15 plugins on WordPress.org, and I have another five premium products that I sell. Including one of which we will be talking about today

Joe: Wow, that’s great. When we were scheduling you to be on the show, we talked about, “Do you want to talk about WP-CRM System?” hich is one of your plugins that you’ve advertised on the show–

Scott: Yeah, sure–

Joe: You’ve acquired a plugin from Pippin, and then we settled on this one about the GDPR, right?

Scott: Correct. I have the five premium products that I sell, you mentioned a couple. WP-CRM System is a CRM that’s baked inside of WordPress, so all of your contact data and everything like that is all stored inside of WordPress. Same idea as why you’d want to host your own site as opposed to using a third party system, as you have control over your data.

Full Screen Background Images is a plugin that you mentioned that I acquired from Pippin. That was just a couple of months ago. End of February, or so. It’s now late May, so a few months ago there.

I have Conditional Checkout Fields which is a plugin for WooCommerce. Or Easy Digital Downloads, which allows you to add fields to the checkout page depending on the products that are in the customer’s cart, so you can collect extra information if you need it.

WP1099 is a plugin that allows you to export 1099 information for tax purposes at the end of the year from affiliates. Or if you have a multi-vendor marketplace, when you need to issue a 1099 to those people, that plugin as well.

And then the plugin we will be talking about today is, it’s called Privacy WP. We’ll get into more about that later on, but as you mentioned it has something to do with the GDPR and things like that.

Joe: Gotcha. I didn’t realize that you did WP1099. You tackle some pretty hard topics as far as running a business in the WordPress space. You’re running a CRM, then issuing 1099’s, which I’ve never done before. I don’t think I’ve ever paid anybody enough to issue a 1099 to them, like as a contractor, right?

Scott: Sure, Yeah.

Joe: I mean, that’s a whole other conversation we can have. But we only have a half hour, and this is going to be information packed. Privacy WP has to do with the GDPR, so let’s start with defining the GDPR, and then how you came up with the idea.

Scott: The GDPR is a regulation coming out of the European Union that revolves around privacy. And as a disclaimer, I’m not a lawyer, and Joe I know you’re not–

Joe: I am not a lawyer either–

Scott: So, none of the stuff that we’re talking about here is legal advice or anything like that. But it’s regulations that revolve around privacy, giving the control back to the individual in terms of what data companies can store on them, and how they can use that data, how they’re able to collect the data and what they can do with it once they have that data, and things like that.

A couple of the key aspects of it that Privacy WP hits on, is that one of the things they need to be able to do is to export data and give that to the individual so that they can see what kind of information you have on them. And then, if they choose to have all that data be erased from your system, you need to be able to do that as well. That’s something that Privacy WP touches on as well.

That’s the gist of the GDPR. Definitely not the legal definition of what it is, or anything like that. If you need more information on that, that there’s plenty of resources out there, or you can always talk to a lawyer who certainly would have more information than I would be able to give you.

Joe: Yeah, absolutely. And just in case it wasn’t clear, when I said as Scott was talking, I’m also not a lawyer. So, definitely don’t consider this legal advice. But I know a lot of people are very worried about it. As we record this, it’s May 21st. May 25th is the day that it goes into effect in the European Union.

I know a lot of people at this point are wondering a couple of things, “What do I need to do to get GDPR compliant? Why do I even need to become GDPR compliant if I’m located in the United States?” And a whole bunch of stuff like that.

And your plugin, I suspect, revolves around some of the latest updates from 4.9.6, is that accurate?

Scott: Yeah, that that’s definitely accurate. Like you mentioned, there’s been some updates to WordPress in the most recent version, which is 4.9.6. What it allows you to do is it allows you to enter in somebody’s e-mail address, or their username on your site. It allows you to go and enter that e-mail address and generate an export file of all the data that you have for that individual on your website, or be able to erase that data from that individual.

For example, if you have comments open on your site or an e-commerce plugin, this feature in WordPress will include any of that data that’s stored on your site for the individual, like the comments or orders, and things like that. WordPress Core Data is included in the export by default, however data from plugins needs to be added in. Commerce, for example, would have to code a solution for including order information in that export.

Since my other plugin, WP-CRM System, is very heavily involved with user data I started working with these features long before they were released to make sure that my plugin was going to be able to work with them correctly. But I got to thinking, “The only way these tools will be able to export erase data is if we tell it to.” And that’s fine for plugins like mine, or WooCommerce, or things like that. But not all data is stored on our websites.

I mean, ideally we’d have all of our data housed under one roof. That way makes life a whole lot easier. But we’ve come to rely on third party apps for things like newsletters, and CRMs, and payment gateways, and a number of other things like that. And so I figured there ought to be a way to include some of that data in the export or erase requests that are built into WordPress. Otherwise users are going to be scrambling to download data from a dozen different sites, and trying to format it in a way that they can send it to people, either through email or some other way.

That’s what Privacy WP does, is it allows you to hook into a number of different third party services or apps that will let you include that data that they have in the export or erase requests.

For example, MailChimp, your email newsletter. You’ll be able to get your subscriber information sent into this built-in solution in WordPress, but it is pulling that data from the third party service.

Joe: Wow, that’s really interesting. I’ve connected MailChimp, I’ve connected ConvertKit and stuff like that. Other third party systems. I also have plugins like LearnDash, which is an LMS. There’s a bit of student data in there. And I guess we’re talking about data, but I think that the distinction is personally identifiable information.

Scott: Right.

Joe: I can have like, “Student X completed this course,” and that’s not personally identifiable information, unless I actually have the user’s name. I can keep the data on completion rates that can say, “14 students of 20 students completed this course,” as long as I don’t have the student’s name or email or IP address associated with it. Right?

Scott: Right. And if any information can be tied back to an individual by itself or in combination with something else, let’s say for example that only one student has ever completed your course. You might be able to tie the fact that that student completed the course.

Like, if you know that I completed your course you’d be able to tie that, “OK, well that’s Scott.” And whatever. You’d be able to tie that back to me at some point.

But if you had a thousand people taking your course, and you have a completion rate of 25 percent, you’re probably not going to tie that back to any one individual. So, I guess each use case is going to be different, and that’s why you need a lawyer.

Joe: That’s really interesting. If one person ever buys my course, any information they have about that course can be tied back to the user, technically, right? Even if I delete all their information from it.

Scott: Yes.

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Joe: That’s very interesting. And a giant pain in the neck, but that’s not what we’re here to talk about. We’re here to talk about how you built this. It sounds like you’re writing, and you’re talking to a lot of API’s and stuff like that. You’re a developer, so let’s get a little bit developer-y. How did how did you build Privacy WP?

Scott: All of this is really new. Even the tools that are built into WordPress is new. It’s just I think last Thursday or Friday or something like that, it came out and they were only introduced in the beta versions of WordPress just a couple of weeks before. So, it’s pretty new.

A lot of it I had to do trial and error because there wasn’t even really a whole lot in terms of documentation with any of this stuff. I had to dig through code and figure out how I was going to build it. And so it was a lot of trial and error work until some sort of documentation slowly started coming about from this stuff. But even with that there were different iterations of the code that in WordPress, that I had to adjust what I was doing and reset there.

Sort of a side note to that point, is if any other plugin developers are looking to add these privacy features into their plugins, I do have a blog post on my site, ScottDeLuzio.com, that shows how to feed the data into the export and erase features that are included in WordPress. It’s a useful resource if you’re struggling to figure it out, you can copy and paste the code example and replace your data with whatever the example has in there. But that’s sort of a side note, not really what we’re talking about.

I’ve also been digging into the API documentation for a bunch of different services, which is sort of time consuming. But it’s also good to see how the different APIs interact with the services, and how you can pull data, what data is available, and stuff like that. Some APIs, like Stripe, are way easier to use than others. I love working with Stripe just because, I mean, it’s a dream to work with. Others, not so much, and they take a little bit longer.

But I think it’s worth it to have a more complete feature set, in terms of the different services that we are going to interact with. That way it becomes more useful for people.

Joe: Gotcha. Yeah, absolutely. So, let’s get a high level overview exactly of how this works, because it’s still being worked on, it’s very new at the time of this recording.

Scott: Sure.

Joe: Ideally we log into WordPress. WordPress has some built-in features, I’ll link to how to access those features. But we enable your plugin, we see a screen where we can connect different services or do we have a report of all the PII that we have?

Scott: Yeah. This plugin is going to be taking data from third party sources, so none of it is really going to be stored on your website at the time of installing the plugin. As a matter of fact, the plugin is not going to store any of the data on your website at all.

What it will do is you’re going to have one setting screen that’s going to have a bunch of fields for API keys, or different settings like that, that you might need to access these different services. I made the plugin to house all of the different integration, so it’s really just one plugin as opposed to one for MailChimp, and one for Stripe, and whatever.

So you have one plug in that will have all these services built into it, you fill in the API keys for the applicable services. If you’re only using MailChimp you just fill in MailChimp’s API keys. And then, as far as the settings go, that’s all you really need to do.

Then you go over to WordPress’ export and erase tools, that you said you’re going to link to.

Joe: Yeah.

Scott: Let’s say you came to me and you said, “I want to see all the data that you have on me.” You’d give me your email address and I fill it into the box in WordPress, in their tool, and I click the “generate export file,” or I forget exactly what the language is on that.

But generate the export file and it will send you a simple HTML page that is a table of all the data from all of the various sources. So, between all the plugins on your site that incorporate with these privacy tools, WordPress itself, like the comments that you’ve left on the site, or if you have a user account on the site, or if you’ve placed any orders through Google or Easy Digital Downloads, things like that. It will all pull in from there.

Then my plugin will say, “OK, what API keys have been entered in?” Like MailChimp, for example. And then they will say, “OK, let’s go to MailChimp and let’s take the email address that we’ve been fed and we’ll go look to see if there’s any e-mail subscribers on my MailChimp lists that match this email address.”

And if so, we’re going to pull in all the data that we have on that particular subscriber. Their names, their e-mail address itself, and the interest lists that you might be subscribed to, when you subscribed, when you last updated, all sorts of information like that, that might be personally identifiable information.

It doesn’t discriminate in terms of what information it pulls, it’s going to pull all of it, and if for some reason you want to include something in that report, well, it’s all being included at this time. And we can play around with filters and things like that if there’s certain information that doesn’t need to be included, then we can we can work with that. But for now I’m pulling in everything and then it gives you a more complete picture and really a one-stop-shop to download the export file.

And then then let’s say you came back to me and said, “I don’t really want to continue doing business with you and I want to have all of my information erased from your website and whatever services you’re using,” then it’s the same kind of thing where it’s that one-stop-shop. I enter in your e-mail address, I click erase, and it goes and it’ll unsubscribe you from MailChimp, it will erase all the information, or anonymize the information from orders in WooCommerce or the comments that you’ve left on the site, and stuff like that.

I mean, technically, yes. Someone could log into MailChimp and say, “OK, does this person subscribe to my newsletter?” And if they do, “OK, now I have to find all the information on that person. I have to now figure out a way to get it to that person.” And it’s kind of a pain to do that.

What this is just trying to do is simplify the whole process. Make it so that you don’t really have to struggle with this data collection and run around to a dozen different services for that.

Joe: Gotcha. That’s very cool. So, WordPress has you covered inside of WordPress, or at least WordPress Core.

Scott: Sure.

Joe: WordPress has you covered. Like, I don’t suspect that this privacy tool will work for LearnDash right out of the box, because LearnDash has it’s own stuff and it probably needs to hook into the new privacy settings. But as far as WordPress Core, they’ve got you covered, your plugin has us covered for some number of third party services that you’re integrating with.

Scott: Correct, yeah.

Joe: And you mentioned something interesting there. It’ll go and anonymize data for orders, because if somebody buys something from me I can’t just straight up delete that order I need that information for tax purposes. Right?

Scott: Right.

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Joe: I at least need the state they’re in and how much they gave me, because if they bought it and they’re in my state I’m going to pay sales tax on that. So with that, I’m not an accountant either. But from what I understand, from what my accountant has told me, I live in Pennsylvania, I am subject to sales tax even on digital goods, therefore I need to know how much money people from inside of my state paid to me.

Scott: Right. And one of the caveats to the whole GDPR thing is that if you’re obligated to keep certain information for other purposes, for legal purposes like taxes and things like that, you might need to keep some of that information even though it is technically personally identifiable information. The fact that that transaction took place, you still need to keep it for a certain period of time. And each state, each country might be different in terms of what that time period might be, whether it’s a year or several years or whatever.

So there’s things like that, and if you are in certain industries they might have certain pieces of information that they need to keep for a certain period of time. I know a lot of people in the insurance industry, they have to keep certain information for certain periods of time. So, each industry and each situation is going to be a little bit different in terms of what can and can’t be erased.

This tool right now is a blanket in terms of exporting the data, it’ll export everything that it possibly can. In terms of erasing data, it tries to be a little bit smart about it. Payment data, like it integrates with Stripe, I mentioned before. Payment data, it’s not necessarily just going to do a hard erase of that entire customer from your Stripe account, because you might need some sort of audit trail with that information.

Joe: Gotcha. And one more thought, obviously this is new so not a lot of changes have happened since launch. I do want to ask about pricing, and plans for the future. But I do want to point out here, that as far as the United States goes at least, this hasn’t even launched yet. At the time of this recording, this hasn’t been tested in the courts of the United States.

Part of me says, “Maybe I should just let it ride and see. Google is going to be the first one that gets sued by the EU.” And that’ll set a legal precedent inside the United States. Then the other part of me reminds me that they are privy to 4 percent of my income as a fee if they determine that I break the rules of GDPR. Right?

Scott: Well, it’s actually technically whichever one is greater, 20 million euros or 4 percent of your last year’s revenue.

Joe: Whichever one is greater?

Scott: Whichever one is greater.

Joe: That’s impossible, I can’t pay that.

Scott: Up to, you know?

Joe: Up to. Right, sure.

Scott: The crazy thing that I heard about this is, read up about this, is that each country within the European Union has their own discretion in terms of how they’re going to enforce these rules and issue punishments and penalties or whatever. And so, some of them could just be a warning. They could say, “Hey, you’re not doing this right. Here’s how you fix it.” And I think that’s going to probably be more along the lines of what the initial things are going to be, just because it is so new, and how you’re going to deal with it.

I think it’s more going to be along the lines of, “Hey, we see you made an effort. You’re not exactly doing it right. Here’s what you can do to fix it.” I think that’s probably going to be the way it goes, but again like you said, this coming Friday hasn’t happened yet. So I don’t know how it’s going to happen.

Joe: Well, I’ll tell you what. If they want 20 million euros from me they’re going to have to come to my house and take me. They can deal with whatever they need to deal with for that.

Scott: Yeah, exactly.

Joe: I think that your plugin is very interesting, you mentioned that this is a premium plugin. I think there’s a very obvious pricing model to me, as far as it works. But why don’t you talk about how you are deciding to price this

Scott: Initially I wanted to build out a different plugin for each third party service. So like, a MailChimp plugin, and a Stripe plugin and everything else. And then I started thinking about it in my mastermind group, and we kicked around some ideas, and someone had mentioned, “Why not just build it all into one plugin and just sell that one plugin?”

And I started thinking about it, and at first I didn’t want to do that because I was thinking, “Oh, now I’m going to have all this code in the plugin that’s not necessary for everyone to have.” But at the same time no one wants to install 15 different plugins to basically do the same thing. And even from a marketing standpoint, even if I price each one of those plugins low, like $5 or $10 dollars, or something like that. If someone had 15 or 20 different third party services that they are integrating with, that 150 or 200 dollar sale is going to be a tougher pill to swallow than one lower price that covers them all.

And so I figured from a marketing perspective, it’d probably be easier to sell at a flat rate, “Here’s that one thing, and any updates you’re going to get new integrations for the duration of your license,” and what not. And I can play around with the pricing as things come up, this is all brand new, it’s just within the last couple of weeks was any of this even possible.

It’s all happened pretty quick and so pricing is one of those things that I thought about along the way, but it wasn’t like top of mind, it was more like, “I need to have a product to sell before I can even worry about price.” So it was almost an afterthought, but not quite that bad.

The other nice thing about having everything in one plugin is that if someone decides to switch to a competing service. So from MailChimp to ConvertKit or something else like that–

Joe: They’re not wasting their money on the add-on.

Scott: Exactly. So it’s like, “Well, I’ve got another six months left on this license and then I’ll have to get the other one.” If everything’s in the same one, it makes it much easier for them to just continue doing business the way they were going to do business.

Joe: Well, that’s very thoughtful. It sounds like way more than an afterthought because my initial thought was you have the core plugin, and then you can maybe pay for the newsletter add-on, and the e-commerce add-on.

But this, I mean as a consumer, somebody who will buy this plugin, I’m very grateful that it’s not the case that I’m going to have to pay individually for each integration. Because a lot of us, especially developers, we’re going to have a lot of integrations because we’re testing different services and trying out stuff.

Scott: Sure. Yeah absolutely.

Joe: It sounds like a lot of thought went into pricing, which is good. I’ve gotten a lot better at thinking about pricing, but it’s always been like, “I’ll just kind of feel my way through pricing right now.” So, you’ve put more thought into it than I have and I think the important takeaway is that you’re going to test it, right? Pricing is never set in stone.

Scott: Right.

Joe: It’s generally easier to increase the price than decrease the price as far as doing right by your current customers I’ve heard.

Scott: Sure, and that’s one thing I didn’t want to have to do is have a crazy price that I would then realize, “Well no one’s buying this, now I’ve got to come down,” and then I’ll have angry customers who didn’t get it at the right price, or whatever. And they’re like, “Well, I need a refund for the difference.”

Joe: Right. You have the one person who buys it at $99 dollars, and then you’re like, “Oh, it’s not selling, I’m going to drop it to $49.” I just paid $50 bucks more than I had to.

Scott: Exactly, right. I like to avoid that at all costs and try to keep people happy. This is supposed to make life easier, not be a headache. So you know, that’s hopefully what it’s going to do.

Joe: Awesome. Well, we are coming up on time. This is perfect. Before I ask you my favorite, my title question, which you said you listen, so you know what it is.

Scott: Sure.

Joe: I do want to ask, what are your plans for the future? Do you have like a prioritized list of integration? Do you want to do filtering next? What’s next on your plate for post-launch?

Scott: One of the things I want to do is, I want to add new services. I don’t have a ton in there right now, so I’m going to check the box on a handful of integrations so I can have something out there and I can start getting some feedback. I’d like to have some sort of poll or survey or something like that on my site that people can vote on the different integrations.

Or they can add in their own integrations, and then people can vote on that, and that type of thing. That’s just one of those things that is added to the to do list and I have to figure out how to do that with still being GDPR compliant. Because the last thing in the world I want to do with this is not be GDPR compliant.

Joe: Right, yeah. So you can e-mail your customers as long as you have explicit opt-in consent to e-mail your customers for polling you.

Scott: Exactly.

Joe: Fantastic. Well, that sounds really good. I’m very excited to continue watching the development of this plugin. Especially as WordPress evolves, and GDPR starts to be implemented and the ramifications for that. I do want to ask you, do you have any trade secrets for us?

Scott: I don’t know if this is really a trade secret or not, or just generally good advice, but I like to make sure that people are taking care of themselves. Not just physically taking care of themselves, but also mentally taking care of themselves.

The last few weeks working on this project has reconfirmed that one of the best things that I can do for myself and my code is to get a good night’s sleep. I can’t tell you how many times I’ve stared at the computer for a long time, trying and struggling to figure something out when something wasn’t working, when I was tired later at night, or whatever.

And then 9 times out of 10 I come back the next morning and I figure it out in about ten minutes. Meanwhile I wasted all that time the night before spinning wheels, and I could have spent my time doing anything else. Hanging out with my family, or just watching TV and letting my brain melt, or whatever.

Also exercise is super important too. I feel that as developers we tend to sit behind desks for long periods of time, and drink tons of coffee or whatever caffeinated beverage of choices. And if you’re feeling sluggish in the morning, do some exercise.

You don’t need to go to the gym, and actually I think going to the gym is sort of an excuse to not do exercise because there’s always that extra step that you have to take just to get there. So then the weather, or car trouble, or time or whatever becomes the excuse for not going to the gym. Just do some push ups, or sit ups, or jumping jacks, or go for a jog or whatever. I don’t know if that’s necessarily a trade secret but it’s what I do.

Joe: It’s great advice and also a little bit counter. I don’t want to take anything away from Gary Vaynerchuk, GaryVee the hustle master. He’s obviously way more successful than I am. But he gives some of the worst advice, like in his last book he said, “Oh, if you have a full-time job, come home from the full time job and work 7:00 to 2:00. Or if you have a family, 9:00 to 3:00.”

I’m like, “I have a 14-month old. I’m not working 7:00am when I get up with my baby, which is generous of her to sleep that long, till 3:00 in the morning. And then what, do the whole thing again in four hours, or five hours? That’s obnoxious.

So, sleep. Get sleep, get rest. You’ll be a lot better for it.

Scott: Absolutely.

Joe: And going to the gym, the barrier for working out is definitely one that rings true for me. I always just viewed my planet fitness subscription as like a fat tax. But now I’ve got two apps for my phone that are great. One is called Carrot Fitness, it’s like 7-minute workouts, it’s awesome. And I have a subscription to Fight Camp. Have you heard of Fight Camp?

Scott: I have heard of it, I haven’t checked it out yet, but I’ve heard of it.

Joe: It’s great. They’re boxing lessons ranging from 15 to 45 minutes, and they just stream them to your phone, they send you punch trackers so I’m learning how to box and I’m closing my exercise ring and my movement ring on my Apple Watch before I even start my day, really.

Scott: That’s great.

Joe: So if you want to work out a home, if you want to heed Scott’s advice, which I recommend you do. Those are two apps, I’ll link them in the show notes for you to check out. Scott, thanks so much for joining me today. Where can people find you?

Scott: You can find me on Twitter. I’m on there quite a bit, @ScottDeLuzio. Or my personal site, ScottDeLuzio.com, and You can find more about Privacy WP at PrivacyWP.com. I’m not very creative with the names like that, but it helps people find it.

Joe: Exactly. That’s the Pippin plugins approach, you know exactly what you’re getting. So I’ll link all of that and more in the show notes. Scott thanks so much for joining me I really appreciate it.

Scott: All right. Thanks for having me.

Joe: And to everybody out there, thanks for listening, thanks to our sponsors. And until next time, get out there and build something.

Outro: Lots of info to take in – but only with your consent of-course! I think Scott was able to highlight a few important bits of GDPR and how we can easy the transition. You should definitely check out his plugin if you use WordPress. And just another reminder – we are not lawyers.

And Thanks again to our sponsors Pantheon and MailPoet. Definitely check them out. They both have FREE offerings for you to try.

For all of the show notes, head over to streamlined.fm/83/. If you like the show, head over to Apple Podcasts and leaving us a rating and review. It helps people discover us! If you want to support the show directly, you can go to patreon.com/howibuiltit and pledge as little as $1/mo for some great extra content. If you’re not quite there yet, you can also join the Facebook community over at streamlined.fm/facebook/

Thanks for joining me, and until next time, get out there and build something!