May 03rd, 2019

Legal Talk 15: Do I Need a Privacy Policy?

​You were thinking of buying a privacy policy template off the internet and wanted to ask me my thoughts.

It's a quick phone call and so I just have a few tips:

1. What's a privacy policy? It's basically a policy where you inform your customer in more detail about how you will be dealing with their personal data. It is often fairly generic. Incorporated into a privacy policy is often a cookie policy just explaining what cookies are (bits of code) and how you will be using them (i.e. to help customers pre-fill forms etc.).

2. Tip: Rather than go through the whole of a privacy policy for you in tedious legal detail, you might just look at the privacy policies that your competitors are using for products which are the same or very similar to yours. These privacy policies will differ slightly depending upon what each competitor is doing with people's data but they will give you a good idea of what you should have in your privacy policy.

3. Any blunders to avoid? There are quite a lot of points where you need to future proof your privacy policy. So, if things are likely to happen in the future (so that you might need to use people's data in different ways in the future and you can foresee this happening) then cater for this in your privacy policy now. 

For example, don't say you will NEVER disclose people's personal data to third parties because what if someone wants to buy your company? In that case you will have to disclose your database of personal data to them so they can see how many customers you have and do some kind of analysis on the value of this customer database. If you have already promised customers that you will not do this then this could hinder the sale of your company in the future! 

Oh, you say. Yes, you will remember that and try to think about ways in which you might use people's data in the future and then try to cater for this in your privacy policy (particularly because you don't want to have to go back to people later on and ask for their consent for particular uses that should have been covered in the first place!). 

Okay, you say, you're going to print out some privacy policies off the internet and try to figure out what kinds of things you might need for your privacy policy. "Good start" I say. Privacy policies are very important, I would suggest doing some extra reading, maybe start here: https://www.privacypolicies.com/blog/privacy-policies-legally-required/.

At that moment, your phone rings. It's news about new investors. You have to go. I pay the bill. My treat. 

I see you walk quickly to the nearest tube station (Hyde Park Corner) and disappear into the underground. I will keep thinking about ways that I can help you to grow your start up faster. 

Until next time,
 
 
Jimmy Desai
Your Legal Coach

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