An External Privacy Notice is a mandatory document required for any organization operating in the Netherlands that processes personal data of individuals. This document must comply with both the EU General Data Protection Regulation (GDPR) and specific Dutch privacy laws, including the Dutch GDPR Implementation Act (UAVG). The notice serves as a primary communication tool between organizations and data subjects, providing transparent information about data processing activities, data subject rights, and compliance measures. It should be written in clear, plain language and must be easily accessible to the public. The External Privacy Notice needs regular reviews and updates to reflect any changes in data processing activities or regulatory requirements, and must be available in languages appropriate for the intended audience, typically including Dutch and English for organizations operating in the Netherlands.
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1. Introduction: Overview of the organization and the purpose of the privacy notice
2. Scope: Who the privacy notice applies to and what activities it covers
3. Data Controller Details: Organization's identity and contact information, including Data Protection Officer if applicable
4. Categories of Personal Data: List and description of personal data types collected and processed
5. Purposes and Legal Bases: Explanation of why personal data is processed and the legal grounds for processing
6. Data Sources: Where and how personal data is collected (directly or from third parties)
7. Data Recipients: Who personal data is shared with, including categories of recipients
8. International Transfers: Information about any data transfers outside the EU/EEA and safeguards applied
9. Retention Periods: How long different types of personal data are kept
10. Data Subject Rights: Explanation of individual rights under GDPR and how to exercise them
11. Complaints Procedure: How to file complaints and contact the supervisory authority
12. Updates to Privacy Notice: How changes will be communicated and managed
1. Cookies and Tracking: Required if the organization operates websites or apps using cookies or similar technologies
2. Automated Decision Making: Required if the organization uses automated processing to make decisions about individuals
3. Special Categories of Data: Required if processing sensitive personal data such as health information or biometric data
4. Children's Privacy: Required if services are offered to or data is collected from children
5. Marketing Communications: Required if personal data is used for direct marketing purposes
6. Employment-Related Processing: Required if notice covers job applicants or employee data processing
7. CCTV and Monitoring: Required if physical surveillance or monitoring systems are in use
1. Cookie List: Detailed list of cookies used, their purposes, and duration
2. Third Party Processors: List of data processors and their roles
3. Data Retention Schedule: Detailed retention periods for different categories of data
4. Technical and Organizational Measures: Overview of security measures implemented to protect personal data
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