Keeping Individuals Informed

April 2018

Under the GDPR you must keep individuals informed about your use of their personal data and about their legal rights relating to that data. Such information is commonly provided on websites by means of Privacy Policies or Privacy Statements. What happens, though, if you want to do business offline?

The GDPR and its information requirements apply whenever you are using personal data. It doesn’t matter whether you’re collecting it, using it, or storing it on a website, in the cloud, on paper, or wherever. If it’s personal data, it’s covered.

What Information do I Need to Supply and When?

The right to be informed is one of the core rights set down by the GDPR. This means that data subjects (e.g. customers) should be told:

- What personal data you hold about them
- What you use that data for
- The legal basis (i.e. grounds) for using it
- How long you will hold it
- Whether you will share the data (and with whom)

Information should also be provided about data subjects’ rights including the right of access and the right to withdraw consent (if applicable).

If personal data is collected directly from the data subjects themselves, this information should be provided at the time the data is collected. If it is collected from a third party, data subjects should be informed within a month, when you first communicate with the data subject, or when you disclose the data to someone else – whichever comes first.

New Privacy Notice

To help in providing this important information, we have now published a new Privacy Notice template which sets out the required information (subject, of course, to you adding some key details) in a user-friendly manner.

Those who have previously used our website privacy policies will find this document instantly familiar. The context, however, is different, as it is designed for use in situations (such as point of sale) where data is being collected somewhere other than a website. After all, as much as it might shock millennials to acknowledge it, not everything is online!

The contents of this Newsletter are for reference purposes only and do not constitute legal advice. Independent legal advice should be sought in relation to any specific legal matter.

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