A GDPR-compliant learning management system (LMS) is essential for organizations handling personal user data.
Such online training systems ensure adherence to data protection regulations, safeguarding user privacy rights, and mitigating the risk of legal penalties and costly fines.
In this article, we’ll review some of the relevant GDPR requirements, how they apply to LMSs, and how to ensure LMSs comply with the GDPR.
Disclaimer: The information below is accurate as of March 21st, 2024.
What is the GDPR?
The General Data Protection Regulation (GDPR) is one of the toughest privacy and security laws in the world.
It affects organizations operating in the European Union or those handling EU customer data.
The GDPR is designed to protect EU citizens’ privacy and personal data by regulating how this information is collected, stored, used, and shared.
Organizations are required to obtain users’ explicit consent before collecting their data. Companies must also explain why they need the user data and how they intend to use it.
Individuals will maintain their right to access, change, or delete their information at any time.
The GDPR also mandates that all organizations implement technological and organizational safeguards to prevent data breaches both “by design” and “by default.”
Data protection by design includes things like data encryption, whereas “by default” refers to the user’s settings being applied at the most privacy-friendly level right from the start.
Let’s see how these data management and protection principles apply to e-learning systems.
How does GDPR apply to learning management systems?
LMSs and other e-learning platforms do a lot of processing of personal data including names, IP addresses, emails, dates of birth, social media information, credit card data, and more.
It’s important to remember that the GDPR is designed to provide data privacy and protection to all citizens located in the European Union.
This means that, even if an LMS operator isn’t located inside the EU but provides training to people who are, the operator must abide by the GDPR.
For this reason, all sensitive information stored within the e-learning system must comply with the regulation.
Non-compliance with the GDPR can incur significant financial penalties like four percent of the company’s entire annual turnover or as much as €20 million.
What steps should be taken to ensure an LMS is GDPR compliant?
Since 2018, when the GDPR came into force, companies have been responsible for how their online learning platforms handle user data.
Although most of today’s LMS providers, like Docebo, comply with the GDPR, it never hurts to make sure.
Here are six steps to ensure your LMS is GDPR-compliant.
- Step 1: Conduct a GDPR audit
- Step 2: Obtain consent from users
- Step 3: Allow data requests
- Step 4: Ensure data security
- Step 5: Control access to personal data
- Step 6: Stay updated
Let’s go over each of these steps in more detail.
1. Conduct a GDPR audit
Start by conducting a full-compliance audit to assess your current standing and identify any potentially vulnerable areas.
Pay close attention to the following areas:
Personal user data: According to the GDPR, organizations should keep data collection to a minimum and only gather necessary information.
Updated privacy policies: Whenever a user is requested to submit any personal data, they need to have access to the latest version of the privacy policy.
- Third-party integrations: Most online training platforms integrate with third-party systems to augment their features and functionalities. If any personal data is exchanged between the two systems, then the third-party tools should also abide by the GDPR.
2. Obtain consent from users
According to the GDPR, companies need to obtain explicit consent from people whenever they collect their personal information.
This means that organizations should have clear and concise privacy policies that explain how users’ data will be used. To comply with this GDPR requirement, companies must have an opt-in form for users to confirm.
Learners should also have the right to revoke their consent at any time and be able to opt out of any forms of communication or cookies at any given time.
3. Allow data requests
The GDPR mandates that all LMS system visitors and learners can request a copy of their personal information (right to data portability) and receive it within a month at no charge.
They can also request the deletion of the data from the company’s database and systems (right to data erasure).
Organizations must abide by these requests and make it easy for users to find and follow the request procedure.
4. Ensure data security
Whether or not companies deal with EU citizens and must abide by the GDPR, data security should still be a top requirement when choosing an LMS.
To implement the GDPR’s “data protection by design,” LMS users should consider the following security features:
- SSL certificates – Security protocols that create an encrypted connection between the browser and the web server. Secure socket layer (SSL) certificates make data transfers impossible to access while the information is in transit.
- Single sign-on (SSO) – A data security feature that allows users to access multiple systems simultaneously by using a single set of login credentials without the risk of password recycling.
- Data encryption – To ensure that information is not stolen, modified, or otherwise compromised, either when the information is in transit between systems or devices or when it is stored in the cloud.
- Strong password requirements – These are included with many professional LMSs like Docebo. For example, they include administrative settings requiring users to create passwords of certain lengths, including numbers, symbols, and upper and lower case letters.
- Regular data backups – These allow the quick restoration of the tool’s operational state in the event of cyberattacks, malware infection, accidental deletion, system failures, or corruption.
5. Control access to personal data
Companies should also ensure that only those with a legitimate reason to access personal user data will have access to it.
LMSs that have the user roles feature should use it to have more control over who has access to personal information within the LMS and who doesn’t.
6. Stay updated
As with any other piece of legislation, the GDPR is subject to change. Organizations should constantly monitor this policy and implement any update notifications to remain compliant.
Is Docebo GDPR compliant?
Yes, Docebo is a GDPR-compliant LMS.
As many of Docebo LMS’s customers operate in the European Union or have EU citizens as platform end users, the online training solution adheres to the GDPR across all of its services.
- Customers can review and sign Docebo’s data processing agreement (DPA).
- Docebo maintains an ISO 27001-certified information security management system (ISMS).
- The platform follows the American Institute of Certified Public Accountants (AICPA) SOC 2. This is a report that evaluates a system’s security, processing integrity, availability, and privacy.
Both ISO 27001 and AICPA SOC 2 ensure Docebo has robust user data–management protocols in line with GDPR Article 32. - Docebo is certified under the Swiss-US and EU-US Privacy Shield frameworks that allow data transfer between the US and both the EU and Switzerland.
Stay GDPR compliant with the right LMS
GDPR compliance is essential for any organization dealing with EU citizens and their personal data.
It helps prevent data breaches, build and maintain trust with end users and other stakeholders, and prevent any costly fines.
Docebo is a GDPR-compliant training solution that offers robust LMS features, advanced security measures, and ongoing compliance updates that ensure data protection and regulatory compliance.
Schedule a demo with Docebo today, and be confident that you’ll always adhere to the GDPR’s strict security requirements.