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Updates to privacy notices

June 28, 2018

Around May 25th, my inbox became filled with emails notifying me that a business was updating its privacy notice because of the GDPR.  While I appreciate knowing that they updated their privacy notice, was it necessary to send an email?

 

The answer is no.  They could have updated their privacy notice, and added a banner to their website notifying me that they had done so.

 

So why did they do it?  Probably because they saw another business doing it, and they thought it would be good public relations to notify their users of their compliance with the GDPR.  While these might have been the external facing reasons, they also had an internal reason - they wanted to ensure that their users "saw" and "agreed" to the updated privacy notice.  While they achieved these goals, they may have annoyed their users because that email became lost in a storm of similar emails around that date.

 

Why do I call it a privacy notice (or statement) instead of a privacy policy.  While this may seem like a unworthy point, there is a good reason to distinguish them.  To me, a privacy notice is a external facing statement telling users, customers, and governmental agencies about how you handle personal information.  And, a privacy policy is an internal facing document that tells employees what they may do with personal information.

 

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