Distinguishing Between a Privacy Notice and a Privacy Policy
by Patrick Oh (rewritten by Alvin Ang)
This is part of a series on :
“Distinguishing Between a Privacy Notice and a Privacy Policy”
When assessing an organization’s commitment to privacy protection, a pivotal indicator can be found by examining their nomenclature for privacy-related documents. It is worth noting that a prevalent misclassification occurs in this context: the mislabeling of a “Privacy Notice” as a “Privacy Policy.” This distinction holds significant implications for both the public and internal stakeholders.
A “Privacy Notice” serves as an outward-facing document designed for public consumption. Its primary purpose is to transparently inform the public about how an organization manages the collection, storage, use, disclosure, transfer, and disposal of their data, ensuring compliance with privacy regulations.
Conversely, a “Privacy Policy” is an internal document intended for the organization’s staff. It delineates the rules, regulations, and obligations that employees must adhere to regarding the provisions outlined in privacy regulations, such as the Personal Data Protection Act (PDPA).
While the core obligations outlined in both documents may align, it is crucial to recognize their intended audiences and purposes. This distinction often eludes even reputable entities, including law firms, privacy consultants, and multinational corporations, who mistakenly refer to their Privacy Notice as a Privacy Policy.
For organizations seeking to draft a Privacy Policy for their staff, a concise and comprehensible approach is highly recommended. Avoid the pitfalls of crafting it in a convoluted, legalese-laden manner that may alienate employees who struggle to decipher its contents. Instead, prioritize clarity and simplicity:
1. **Conciseness**: Keep the document brief and straightforward, eschewing complex legal jargon that may hinder comprehension. The goal is to ensure that all staff members can readily grasp the content.
2. **Sequential Obligations**: Arrange the obligations logically, ideally mirroring the data flow cycle (Collection, Storage, Use & Disclosure, Transfer, Disposal). This organization aids employees in understanding the sequence of actions they must undertake.
3. **Action-Oriented Language**: Utilize action verbs to convey that the Privacy Policy is a directive document, not merely an informational one. Encourage staff to take specific actions in line with the policy’s provisions.
In conclusion, it is essential to recognize that the purpose of an organization’s policy is not to showcase complexity or impress readers, but rather to facilitate seamless implementation. Clarity and simplicity should be the guiding principles when drafting privacy-related documents, ensuring that both the public and internal stakeholders can easily understand and adhere to the organization’s commitment to privacy protection.
About Patrick Oh
Patrick is Singapore Certified Management Consultant providing PDPA compliance consultancy, Performance management and Solutions Design and Development.
https://www.linkedin.com/in/patrick-oh-sglion65/
About Dr. Alvin Ang
Dr. Alvin Ang earned his Ph.D., Masters and Bachelor degrees from NTU, Singapore. Previously he was a Principal Consultant (Data Science) as well as an Assistant Professor. He was also 8 years SUSS adjunct lecturer. His focus and interest is in the area of real world data science. Though an operational researcher by study, his passion for practical applications outweigh his academic background He is a scientist, entrepreneur, as well as a personal/business advisor.
More about him at www.AlvinAng.sg.
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