Privacy, Data Protection & Digital Sovereignty FrameworkDraft Framework — Not Adopted Policy
Legal & Curatorial Compliance Drafting Template

Privacy, Data Protection & Digital Sovereignty

A draft framework describing the principles IPS may use when evaluating website privacy, data minimization, security, consent, records handling, and culturally sensitive information.

Draft Framework — Not Adopted Policy

This page is an organizational drafting template, not a statement of implemented legal compliance. IPS has not yet adopted a final privacy policy, appointed a privacy officer, established a subject-access system, approved retention schedules, or documented every hosting and third-party data flow. The framework requires legal, technical, governance, and operational review before it can become policy.

StatusDraft framework
Effective dateNot established
Last reviewedReview date not published
Policy ownerNot assigned
JurisdictionNot determined
VersionWorking draft
IPS Drafting Protocol
Section 01 // Scope

1. Purpose and Scope

This page documents proposed privacy principles under consideration by the International Pagan Society. It applies only to future IPS-controlled website services, and only after any resulting policy is formally adopted. It does not create contractual rights and is not legal advice.

This draft does not claim present compliance with the GDPR, UK GDPR, CCPA/CPRA, COPPA, HIPAA, FERPA, PCI DSS, or any other data-protection law. Adoption of a final policy would require jurisdiction-specific legal counsel.

Nothing on this page should be read as stating that IPS is a controller, processor, charity, company, trust, foundation, archive, employer, university, publisher, religious institution, or otherwise regulated entity, except where that status is independently verified.

Section 02 // Inventory

2. Current Website Data Flows

This inventory is based strictly on inspection of the website's source code. It lists only features actually present in the repository.

Website featureCurrent statusPossible data involvedDestination or processorVerification status
Basic page requestsStatic pages served on requestIP address and standard technical request data may be processed by hosting/CDN infrastructureHosting infrastructure details require deployment-level verificationRequires deployment verification
Footer newsletter signupInterface present; input and submit button disabled in sourceEmail address, if ever enabledNo mailing-list service connected in sourceConfirmed disabled in source
Contact & Correspondence frameworkDisabled preview form; entire fieldset is disabledName, email, jurisdiction, subject, message, if ever enabledNo intake service connected in sourceConfirmed disabled in source
Frequently Asked Questions search previewDisabled input and buttonNoneNot applicableConfirmed disabled in source
Site search & discovery previewDisabled filters and controlsNoneNot applicableConfirmed disabled in source
Press & media inquiry formDisabled preview formName, organization, email, topic, if ever enabledNo intake service connected in sourceConfirmed disabled in source
Donate page (one-time USD donation)Active external link to Stripe's hosted checkout; no local formNone collected by this website; payment and contact details are entered only on StripeStripe (donate.stripe.com or buy.stripe.com)Confirmed in source — this site stores no card or payment data
Other donation pages (Ways to Give, Why Donate, Institutional Giving)Static informational pages; disabled inquiry forms for alternative giving channelsContact/inquiry fields only, if ever enabled; no card data is present in sourceNot connectedConfirmed disabled in source
Donation success & canceled templatesStatic design previews; source comments confirm they do not read query parameters, cookies, or transaction stateNoneNot applicableConfirmed in source
Volunteer, fellowship & partnership application formsDisabled preview formsApplication fields, if ever enabledNot connectedConfirmed disabled in source
Header mobile-menu toggleLocal browser script onlyNone collected or transmittedRuns entirely in the visitor's browserConfirmed in source
External links (partners, references, etc.)Standard hyperlinksNone collected by IPS by leaving this websiteThe destination site's own practices apply once a visitor leavesNot applicable

Hosting infrastructure details require deployment-level verification. No hosting, CDN, analytics, or email-delivery provider is named in this repository, and none should be inferred.

Section 03 // Principles

3. Proposed Data-Minimization Principles

Proposed principles — not verified operational controls
  • Collect only what is necessary for a specific, disclosed purpose
  • Define a lawful, disclosed purpose before any collection begins
  • Avoid collecting sensitive-category data by default
  • Minimize free-text fields that could invite unnecessary disclosure
  • Restrict access to any personal data on a need-to-know basis
  • Avoid indefinite retention of personal records
  • Verify any third-party processor before it is connected
  • Document deletion procedures before intake begins
  • Provide transparent, plain-language notices at the point of collection
  • Apply privacy-by-design and privacy-by-default to any future feature
Section 05 // Third Parties

5. Cookies, Analytics and Third Parties

No first-party analytics, advertising tracker, consent manager, or nonessential cookie implementation was identified in the reviewed source code. This does not replace verification of hosting-layer logs, deployment settings, embedded third-party services, or future integrations.

CategoryStatus
Essential browser/site operationNot identified in source
AnalyticsNot identified in source
AdvertisingNot identified in source
Embedded mediaNot identified in source
Payment processingNot set by this website — Stripe's hosted checkout is a separate site
Newsletter/emailNot connected
External linksFuture integration not approved
Section 06 // Records

6. Forms, Communications and Records

Every form currently present on this website is a natively disabled visual preview. None of them submit, store, upload, email, or transmit information. The Footer newsletter form exists as an interface only and is not connected to a mailing list.

Form or controlLocationOperational status
Footer newsletter signupSitewide footerInactive visual preview
Correspondence intake worksheet/contact/Inactive visual preview
FAQ search preview/questions/Inactive visual preview
Site search & discovery preview/search/Inactive visual preview
Media inquiry form/press/Inactive visual preview
Giving inquiry form/donate/ways-to-give/Inactive visual preview
Donate button (links to Stripe)/donate/Active external link — no local form
Institutional giving inquiry/donate/institutional-giving/Inactive visual preview
Volunteer & fellowship applications/get-involved/volunteer/Inactive visual preview
Partnership application/about/partnerships/application/Inactive visual preview
Dispatches subscribe form/dispatches/Inactive visual preview

No claim is made about encryption, confidentiality, deletion, access restrictions, or retention periods for these forms, because none of them are currently operational.

Section 07 // Payments

7. Donations and Payment Processing

The Donate page links to a Stripe-hosted Payment Link for one-time USD donations. Payment-card numbers, bank details, and billing information are entered only on Stripe's own checkout page and are never collected, transmitted, or stored by this website or its hosting infrastructure.

Source-code comments on the donation success and canceled templates confirm that those pages do not read query parameters, cookies, or any client-side state to determine transaction status. This website does not redirect Stripe checkout to those templates in this release.

A future server-side payment integration — transaction verification, webhook handling, donor-records controls, a refund policy, and independent security review — would require its own payment-specific privacy disclosures before it could be enabled. This draft does not claim PCI DSS compliance, and no receipts, donor records, recurring payments, tax records, refunds, or financial profiles are generated or stored by this website.

Section 08 // Digital Sovereignty

8. Cultural and Archival Sensitivity

Any future archival or repository work would need to apply heightened care to culturally sensitive material, sacred or restricted knowledge, oral histories, and community provenance. Proposed considerations include Indigenous or traditional-knowledge protocols, contributor consent, removal and correction requests, contextual integrity, access restrictions, community authority, and archival dignity.

No cultural-data governance, community-consent, restricted-access, archival-intake, or traditional-knowledge protocol has yet been adopted.

Nothing in this section should be read as a claim of ownership, custody, jurisdiction, or authority over any culture, tradition, or community.

Section 09 // Requests

9. Individual Rights and Requests

Legal rights over personal data depend on jurisdiction, organizational status, the specific data processing involved, and applicable law. This page does not state that every visitor automatically holds GDPR or other statutory rights through IPS.

No verified subject-access request system currently exists. No privacy officer or data-protection officer is currently published. No formal verification, correction, portability, objection, restriction, or deletion process has been adopted. Future procedures would require legal and security review, and no response deadline is promised here.

Access

Procedure not established

Correction

Procedure not established

Deletion

Procedure not established

Restriction or Objection

Procedure not established

Portability

Procedure not established

Complaint or Escalation

Procedure not established
Section 10 // Accountability

10. Security, Retention and Accountability

A future policy could propose a control framework including:

  • Access control
  • Least privilege
  • Secure configuration
  • Dependency updates
  • Secret management
  • Backups
  • Logging
  • Incident response
  • Breach assessment
  • Vendor review
  • Data inventory
  • Retention schedules
  • Deletion verification
  • Policy review
  • Staff and volunteer training

Listing a control does not mean it is implemented, audited, certified, or continuously monitored. This draft does not claim encryption at rest, encryption in transit beyond ordinary HTTPS assumptions, ISO 27001, SOC 2, Cyber Essentials, penetration testing, vulnerability scanning, 24/7 monitoring, disaster recovery, data residency, geographic redundancy, immutable backups, certified deletion, privacy audits, or named security personnel, unless independently verified.

Proposed Retention Categories

Data or record categoryCurrent collection statusProposed retention approachApproval required
Hosting request logsProcessor behavior requires verificationNo schedule adoptedLegal and technical review required
Newsletter submissionsNot collected by current pageRetention period not establishedLegal review required
Contact inquiriesNot collected by current pageRetention period not establishedLegal review required
Donation recordsNot collected by current pageRetention period not establishedLegal, financial review required
Media inquiriesNot collected by current pageRetention period not establishedLegal review required
Volunteer/application informationNot collected by current pageRetention period not establishedLegal review required
Safeguarding reportsNot collected by current pageNo schedule adoptedLegal, safeguarding review required
Archival submissionsNot collected by current pageNo schedule adoptedLegal, cultural-governance review required
Consent recordsNot collected by current pageRetention period not establishedLegal review required
Analytics dataNot collected by current pageNot applicableLegal review required if ever introduced
Statutory Data Subject Exercise Portal — Preview

Subject or Data Request Framework

No subject-access, deletion, correction, portability, privacy-complaint, or data-rights request system is currently connected to this website. The disabled fields below illustrate a possible future intake structure only.

Subject or data request preview (all fields disabled)

This preview does not submit, store, verify, or transmit any information. No database, email, upload, or identity verification is connected to it.

Review the Contact & Correspondence Framework— that page is also a static framework and is not itself a functioning data-rights intake channel.