The Privacy Notice Statement is a mandatory document under UAE Federal Decree-Law No. 45 of 2021, required for organizations that collect and process personal data within the UAE jurisdiction. This document must be provided to data subjects before or at the time of data collection, explaining how their personal data will be handled. It needs to address requirements from both federal law and, where applicable, specific regulations from free zones such as DIFC and ADGM. The Privacy Notice Statement should be clear, accessible, and comprehensive, covering all aspects of data processing activities, security measures, data subject rights, and international transfer mechanisms. It serves as a crucial compliance tool and helps organizations maintain transparency in their data processing activities.
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1. Introduction: Overview of the privacy notice and its purpose
2. Scope and Applicability: Who the privacy notice applies to and what activities it covers
3. Definitions: Key terms used throughout the privacy notice, aligned with UAE law definitions
4. Types of Personal Data Collected: Detailed categorization of personal data collected and processed
5. Legal Basis for Processing: Legal grounds under UAE law for collecting and processing personal data
6. Purposes of Processing: Specific purposes for which personal data is collected and used
7. Data Subject Rights: Rights of individuals under UAE data protection law and how to exercise them
8. Data Security Measures: Overview of technical and organizational measures to protect personal data
9. Data Retention: How long personal data is kept and criteria for determining retention periods
10. International Data Transfers: Information about cross-border data transfers and safeguards
11. Contact Information: Details of the data controller and how to contact for privacy matters
12. Updates to Privacy Notice: How changes to the privacy notice will be communicated
1. Specific Processing Activities: Detailed section for organizations with complex data processing operations requiring additional explanation
2. Cookies and Tracking Technologies: Required for organizations operating websites or online services that use tracking technologies
3. Children's Privacy: Required if services or products may be accessed by or target children
4. DIFC/ADGM Specific Provisions: Required for organizations operating in these free zones to address additional requirements
5. Sector-Specific Disclosures: Additional disclosures required for specific sectors (e.g., healthcare, financial services)
6. Marketing Communications: Required if personal data is used for marketing purposes
7. Automated Decision Making: Required if the organization uses automated processing to make decisions about individuals
8. Employee Data Processing: Required for organizations processing employee personal data
1. Data Processing Activities Register: Detailed list of data processing activities and their purposes
2. Categories of Recipients: List of third parties with whom personal data is shared
3. Technical and Organizational Measures: Detailed description of security measures implemented
4. Data Subject Request Procedures: Detailed procedures for handling data subject rights requests
5. Retention Schedule: Detailed retention periods for different categories of personal data
6. Cross-border Transfer Mechanisms: Details of mechanisms used for international data transfers
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