Website Privacy Policy - Basic - No Cookies
This Website Privacy Policy template has been designed for use with websites that only collect limited personal data from users, without using cookies. An example may be a site that uses a basic ‘Contact Us’ form.
This document has been written with the UK GDPR in mind, covering important elements such as details of data subjects' rights, information on the retention of personal data (i.e. for how long it will be kept), and data subject access requests.
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 on the personal data that you collect and how it is collected, both detail and user-friendliness are important. Using technical jargon is not a good idea. It is also important to note that, where personal data is obtained 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 located inside or outside the UK. Provide as much detail here as you can.
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 would estimate, 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 choose to rely on ‘legitimate interests’, you should explain what those interests are in your privacy policy.
A related issue is that of automated decision-making and/or profiling. The law incorporates additional restrictions and rights relating to this kind of personal 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 policy. 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 provide details of the technical or scientific logic used in the automated process, however. Instead, you should tell individuals about the data that you use and why, 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 retain personal data? This is an important piece of information to give to data subjects. 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 others will not. Legal advice should always be sought if there is any doubt. Please note that example retention periods are not included in this template.
Another key point relates to data security. Data subjects 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 sites. 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.
This Basic Website Privacy Policy contains the following clauses:
1. Information About [Us] OR [Me]
2. What Does This Policy Cover?
3. What Is Personal Data?
4. What Are My Rights?
5. What 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. Can I Withhold Information?
11. How Can I Access My Personal Data?
12. How Do I Contact You?
13. Changes to this Privacy Policy
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