personal data about and/or from their users, and that use first-party
cookies. First-party cookies are those which are set directly by the
compliance with the group of laws collectively referred to as “Cookie 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 standalone Cookie
This document has been written with the GDPR in mind, covering important
aspects 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 on the personal data that you collect and how you do
so, both detail and user-friendliness are important. Technical terminology
should be avoided wherever possible. 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 situated inside or outside the EEA. 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 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
Another aspect of personal data use is 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,
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 explain the scientific and technical logic used
in the automated process, however. 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,
You must also tell data subjects how long you are going to retain their
personal data (or at least the factors that will determine how long). When
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 personal data security. 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
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?
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