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Who we are?
Provide name and contact details of the data controller. This will typically be
your business or you, if you are a sole trader. Where applicable, you should
include the identity and contact details of the controller’s representative
and/or the data protection officer.
What information do we collect?
Specify the types of personal information you collect, eg names, addresses, user
names, etc. You should include specific details on:
how you collect data (eg when a user registers, purchases or uses your services,
completes a contact form, signs up to a newsletter, etc)
what specific data you collect through each of the data collection method
if you collect data from third parties, you must specify categories of data and
source
if you process sensitive personal data or financial information, and how you
handle this
You may want to provide the user with relevant definitions in relation to
personal data and sensitive personal data.
How do we use personal information?
Describe in detail all the service- and business-related purposes for which you
will process data. For example, this may include things like:
personalisation of content, business information or user experience
account set up and administration
delivering marketing and events communication
carrying out polls and surveys
internal research and development purposes
providing goods and services
legal obligations (eg prevention of fraud)
meeting internal audit requirements
Please note this list is not exhaustive. You will need to record all purposes
for which you process personal data.
What legal basis do we have for processing your personal data?
Describe the relevant processing conditions contained within the GDPR. There are
six possible legal grounds:
consent
contract
legitimate interests
vital interests
public task
legal obligation
Provide detailed information on all grounds that apply to your processing, and
why. If you rely on consent, explain how individuals can withdraw and manage
their consent. If you rely on legitimate interests, explain clearly what these
are.
If you’re processing special category personal data, you will have to satisfy at
least one of the six processing conditions, as well as additional requirements
for processing under the GDPR. Provide information on all additional grounds
that apply.
When do we share personal data?
Explain that you will treat personal data confidentially and describe the
circumstances when you might disclose or share it. Eg, when necessary to provide
your services or conduct your business operations, as outlined in your purposes
for processing. You should provide information on:
how you will share the data
what safeguards you will have in place
what parties you may share the data with and why
Where do we store and process personal data?
If applicable, explain if you intend to store and process data outside of the
data subject’s home country. Outline the steps you will take to ensure the data
is processed according to your privacy policy and the applicable law of the
country where data is located.
If you transfer data outside the European Economic Area, outline the measures
you will put in place to provide an appropriate level of data privacy
protection. Eg contractual clauses, data transfer agreements, etc.
How do we secure personal data?
Describe your approach to data security and the technologies and procedures you
use to protect personal information. For example, these may be measures:
to protect data against accidental loss
to prevent unauthorised access, use, destruction or disclosure
to ensure business continuity and disaster recovery
to restrict access to personal information
to conduct privacy impact assessments in accordance with the law and your
business policies
to train staff and contractors on data security
to manage third party risks, through use of contracts and security reviews
Please note this list is not exhaustive. You should record all mechanisms you
rely on to protect personal data. You should also state if your organisation
adheres to certain accepted standards or regulatory requirements.
How long do we keep your personal data for?
Provide specific information on the length of time you will keep the information
for in relation to each processing purpose. The GDPR requires you to retain data
for no longer than reasonably necessary. Include details of your data or records
retention schedules, or link to additional resources where these are published.
If you cannot state a specific period, you need to set out the criteria you will
apply to determine how long to keep the data for (eg local laws, contractual
obligations, etc)
You should also outline how you securely dispose of data after you no longer
need it.
Your rights in relation to personal data
Under the GDPR, you must respect the right of data subjects to access and
control their personal data. In your privacy notice, you must outline their
rights in respect of:
access to personal information
correction and deletion
withdrawal of consent (if processing data on condition of consent)
data portability
restriction of processing and objection
lodging a complaint with the Information Commissioner’s Office
You should explain how individuals can exercise their rights, and how you plan
to respond to subject data requests. State if any relevant exemptions may apply
and set out any identity verifications procedures you may rely on.
Include details of the circumstances where data subject rights may be limited,
eg if fulfilling the data subject request may expose personal data about another
person, or if you’re asked to delete data which you are required to keep by law.
Use of automated decision-making and profiling
Where you use profiling or other automated decision-making, you must disclose
this in your privacy policy. In such cases, you must provide details on
existence of any automated decision-making, together with information about the
logic involved, and the likely significance and consequences of the processing
of the individual.
How to contact us?
Explain how data subject can get in touch if they have questions or concerns
about your privacy practices, their personal information, or if they wish to
file a complaint. Describe all ways in which they can contact you – eg online,
by email or postal mail.
If applicable, you may also include information on:
Use of cookies and other technologies
You may include a link to further information, or describe within the policy if
you intend to set and use cookies, tracking and similar technologies to store
and manage user preferences on your website, advertise, enable content or
otherwise analyse user and usage data. Provide information on what types of
cookies and technologies you use, why you use them and how an individual can
control and manage them.
Linking to other websites / third party content
If you link to external sites and resources from your website, be specific on
whether this constitutes endorsement, and if you take any responsibility for the
content (or information contained within) any linked website.
You may wish to consider adding other optional clauses to your privacy policy,
depending on your business’ circumstances.
