What Must Be Included in a Privacy Policy?

A privacy policy, also known as a privacy notice, is a document that explains how an organisation collects, uses, and manages personal data. It should clearly identify who is responsible for the data, including the data controller and any processors involved, so individuals know who to contact regarding their information. The policy should also specify what types of personal data are being collected or processed and explain why this data is being collected, including the lawful basis for processing under the UK GDPR. If any special category data is processed, the policy should outline the legal justification for that as well.

In addition, a privacy policy should explain where the data comes from if it was not collected directly from the individual. It should outline how long the data will be retained and the measures in place to protect it from unauthorised access or misuse. The policy must also clarify who the data is shared with, why it is shared, and what the recipients are allowed to do with it. Individuals should be informed about their rights over their personal data, including the right to access, correct, delete, or withdraw consent, and how they can exercise these rights.

A good privacy policy should also provide contact information for the organisation’s data protection lead and for the Information Commissioner’s Office (ICO) in case individuals have concerns or wish to make a complaint. Finally, it should describe any significant changes to how personal data is processed, ensuring transparency. The language of the policy should be clear, concise, and accessible, avoiding technical or legal jargon so that individuals can easily understand how their personal data is handled. Regular review and updates are recommended to reflect any changes in processing practices.