information about and/or from their users, using both first and third-party
cookies. First-party cookies are those which are set directly by the
website itself. Third-party cookies are set by another site, domain, or
compliance with the group of laws referred to as “Cookie Law”. This policy
can assist in compliance with the various requirements laid down by the
law. In particular, the policy explains what cookies your site uses, what
for, and why. Alternatively, if you wish to provide more detailed
information on cookies, this document can be altered to refer to a separate
This document has also been written with the GDPR in mind, covering
important points such as details of data subjects' rights, information on
the retention of personal data (i.e. for how long it will be kept), data
subject access requests, and controls and/or consent for cookies and
This template has been reviewed and updated in light of best practice which
has become established since the GDPR came into effect in May 2018. More
detail is provided to data subjects in a number of key areas, including how
personal data is collected, the source of that data, how it is used, and
how it is shared. Furthermore, references to the Data Protection Act 2018
have been added to help make for a smoother Brexit transition in 2019.
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
When providing details of the personal data that you collect and how you
collect it, both detail and user-friendliness are important. Using
impenetrable tech jargon will not serve you well here. 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 private or public). It may also be helpful to indicate
whether the source is inside or outside the EEA. 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
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
‘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,
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
policy, 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 websites. When
completing this template, ensure that your policy 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.
1. Definitions and Interpretation
2. Information About [Us] OR [Me]
3. What Does This Policy Cover?
4. What Is Personal Data?
5. What Are My Rights?
6. What Data Do You Collect and How?
7. How Do You Use My Personal Data?
8. How Long Will You Keep My Personal Data?
9. How and Where Do You Store or Transfer My Personal Data?
10. Do You Share My Personal Data?
11. How Can I Control My Personal Data?
12. Can I Withhold Information?
13. How Can I Access My Personal Data?
15. How Do I Contact You?
Either enter the requisite details in the highlighted fields or adjust the
wording to suit your purposes.
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