Website Privacy Policy Template (First Party Cookies)

Website Privacy Policy - First Party Cookies (GDPR-Ready)

BS.WEB.PRIV.03

This Website Privacy Policy is designed for use on websites that gather 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 website itself.

Important parts of this policy template address the use of cookies and 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 Policy.

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 related technologies.

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 required.

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 to explain what those interests are in your privacy policy.

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, 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 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, here.

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 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 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 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.

This Website Privacy Policy contains the following clauses:
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?
14. How Do You Use Cookies?
15. How Do I Contact You?
16. Changes to this Privacy Policy

This privacy policy template is in open format. Either enter the requisite details in the highlighted fields or adjust the wording to suit your purposes.

Once you have purchased access to the appropriate document folder click on the “Download Document” link below. You will be asked what you want to do with the file. It is recommended that you save the document to a location of your choice prior to viewing.

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