Agree. But if a company embraces art. 25 on Data Minimization it becomes simple to link data to purpose and communicate that in a consent request, if as we do, you do it incrementally as data is accessed. Simplified consent and compliance to an article few pay attention to
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Agree on minimisation, but consent is a red herring. In fact it’s the processing *not* based on consent which is usually so poorly explained in privacy info
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Design Privacy Pages like a Product Page, as did Applehttps://www.apple.com/privacy/
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The idea has merit, but that particular execution doesn’t give meaningful info about the processing that Apple carries out on personal data, so it doesn’t fit the bill. You have to dig down into the contract-like Ts&Cs to get that info - definitely a GDPR transparency fail
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My argument is that that's because the intended audience of the privacy policy is regulators, not customers
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Agree; most are written for auditors not the data subjects’ right to be informed. Failure to meet transparency requirements though, so any auditor that gave it a pass would be doing a poor job
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Those who 'draft' policies (= taking someone else's, and making a bad job of changing the names and otherwise disguising the fact that no thought has much been given to whether 'it fits') usu. forget that a policy is meant to inform / be the basis of *a procedure* ?
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That’s a general problem with policies, yes - in the case of privacy notices, they are mistaken in believing that it is even a ‘policy’ at all. It’s not - it’s a description for the data subject of why/when/where/how their data is being used
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It’s not an either-or, there are other ways....
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