Privacy Notice Template
This Privacy Notice template is designed to provide important information about your use of personal data to data subjects, as required by the UK GDPR and the Data Protection Act 2018.
This template is very similar to our website privacy policies, but it is designed primarily for use offline (or at least with offline data collection).
This document has been updated for compatibility with the UK GDPR. It is ready for use from the start of 2021.
This document has been designed for general application, however please note that you may require specific legal advice if you deal with ‘special category’ (aka ‘sensitive’) personal data, data relating to criminal convictions, or children’s personal data as additional measures may be required.
When providing details of the personal data that you collect and how it is collected, both detail and user-friendliness are important. Keep things as clear and simple as you can (which, it must be said, is not always easy given the complexity of the subject matter). It is also important to note that, where data is sourced from a third party, you specify what type of organisation that third party is (e.g. its industry or sector, and whether it is a private or public organisation). It may also be helpful to indicate whether the third-party source is located inside or outside the UK. Provide as much detail here as is commercially reasonable.
It is important to explain how you use the personal data that you collect and the ‘lawful basis’ which allows you to do so. There are several lawful bases to choose from, as explained on the ICO website, here. Consent, the data being necessary for a contract, or ‘legitimate interests’ are, we suggest, the most likely bases for many businesses; however, it is important to take care when choosing. ‘Consent’ may appear to be the most straightforward, but this is often not the case. Furthermore, if you opt to rely on ‘legitimate interests’, it is important to explain what those interests are in your privacy notice.
Also under the ‘use’ heading comes automated decision-making and/or profiling. The law features additional restrictions and rights relating to this kind of data processing, but it is important to note that these only apply where the resulting decision has ‘a legal or similarly significant effect’. When carrying out such decision-making or profiling, you should explain it in your privacy notice. The law requires you to provide ‘meaningful information about the logic’ and to explain ‘the significance and envisaged consequences’ of the process. This is not intended to require you to break down the programming logic used in the automated process, however. Rather, you should tell individuals what data you use and why, and what the likely result is going to be and how likely it is to affect them. It is always important to keep your information as clear and easy-to-understand as you can. More information about automated decision-making and profiling is available on the ICO website, here.
How long do you keep personal data? This is an important question to which individuals need to know the answer. When dealing with this in your privacy notice, it is important to be as specific as possible. It is also important to keep in mind that some data retention periods may be specified by law, but this will not apply in many cases. Legal advice should always be sought if there is any doubt. Please note that example retention periods are not included in this template.
A further important point to note relates to your data security arrangements. Users should be able to understand what you are doing to keep their personal data safe. When setting out measures such as encryption, ensuring on-going confidentiality, and recovering data in the event of loss, be sure to use user-friendly language.
Finally, it is important to note that the provisions included in this template are broad and will not necessarily apply to all situations. When completing this template, ensure that your privacy notice accurately reflects your actual use of personal data and associated procedures.
Optional phrases / clauses are enclosed in square brackets. These should be read carefully and selected so as to be compatible with one another. Unused options should be removed from the document.
This Privacy Notice contains the following parts:
1. Information About [Us] OR [Me]
2. What Does This Notice Cover?
3. What Is Personal Data?
4. What Are My Rights?
5. What Personal Data Do You Collect and How?
6. How Do You Use My Personal Data?
7. How Long Will You Keep My Personal Data?
8. How and Where Do You Store or Transfer My Personal Data?
9. Do You Share My Personal Data?
10. How Can I Access My Personal Data?
11. How Do I Contact You?
12. Changes to this Privacy Notice
This Privacy Notice is in open format. Either enter the requisite details in the highlighted fields or adjust the wording to suit your purposes.
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