A Privacy Notice is a published document at the attention of the data subjects that explains why the controlling service concerned processes personal data, details its processing operations and informs data subjects of their rights.
Data subjects have the right to be informed of several details relating to the processing of their data: transparency is a key principle. Therefore, a Privacy Notice must be available at the attentention of the data subjects concerned.
A Privacy Notice is a document that provides information on the processing activities carried out by a Controlling Service. It describes how the Controlling Service collects, uses, retains and discloses the personal information.
This document must be:
- Concise, transparent, comprehensible and easily accessible
- Clear and written in plain language and easy to understand.
For the sake of transparence, Controlling services in charge of diverse processing activities, should consider to set-up several privacy notices, in particular
when the processing activities concern different groups of data subjects.
Example: Service A, in charge of Internal Training courses, handles personal data of course participants (e.g. to organise the classes, to monitor progress, to issue diplomas) and of external trainers (e.g. to organise the classes, to establish the billing to the contractor),
when the processing of the same data is based on different lawful bases.
Example: Service B processes the e-mail address of its clients for the execution of a contract (in the context of the daily business) and based on consent (for a survey to measure the satisfation of its clients),
when the processing activities have different overall purposes.
Example: Service C is in charge of Duty Travel Management and of Family Allowances.
If data is collected directly from someone, the privacy notice has to be provided at the moment when they disclose their data. This could be by adding a link to the privacy notice on the web form concerned, or by displaying the URL of the privacy notice on the paper form.