In the interests of transparency, regulations compel you to communicate certain details around the ways in which you collect and use personal information. It is important for individuals to understand your organization’s approach to protecting personal information. You also need to provide individuals with access to their personal information. In this section, you will find the necessary templates and the code which you can embed in your organization’s websites for both your Organizational Privacy Notice and your Employee Privacy Notice.
The Privacy Notices Homepage links to both Privacy Notices.
Privacy Notice (Organization)
A Privacy Notice draws special attention to your organization’s approach to compliance – especially where you collect personal information online. Your Privacy Notice must be displayed wherever you are about to collect personal information.
When you enter the Organization Privacy Notice section, you may dismiss the introduction by clicking the “X”. The page begins with section tabs, and also displays your auto-generated Privacy Notice.
Privacy Notice tab
You must begin in the “Privacy Notice” creation tab. You cannot use the “Integration” tab until your notice is “Published”.
The Privacy Notice tab shows content creation options and document status information.
If your organization will not use this Privacy Notice, choose Status = N/A.
Create Privacy Notice
The first step is to choose your creation method:
- Use template: uses a provided template; content cannot be changed
- Use my own content: begins with a provided template; then you modify content
- Use my own document: you upload an externally created PDF document which contains your content
If you are not sure which method to use, we recommend that you “Use template” and consult with your legal counsel.
WARNING: Caution if changing creation method – After you choose a content creation method, use extreme caution if you decide to change methods. Changing methods will cause all edited or uploaded content to be deleted and it cannot be recovered. There is a pop-up reminder where you must confirm your choice. If you change methods we recommend that you download a copy of your existing version before clicking the new option.
Use template
DPDx provides a template of a Privacy Notice with essential elements informed by US regulation. Additionally, custom content is drawn from these sections in DPDx: Organization Setup, Data Mapping, Service Providers, and Third Parties.
When you make changes to the DPDx sections that filter through to the Privacy Notice, the Draft version of your Template Notice will also be updated dynamically to show these changes. See the section below, Edit a notice, for instructions on Publishing an updated notice.
You cannot make any changes to the text in a Template Notice.
The following sections are included in the template:
- Our Organization
- What we do with your personal information
- What personal information do we collect?
- Use of Cookies
- IP Addresses
- Email Information
- We collect your personal information from the following indirect sources
- Who might we share your personal information with?
- How do we look after personal information?
- Email Policies
- CAN-SPAM Compliance
- How Do We Protect Your Information and Secure Information Transmissions?
- How can you access your personal information?
- Choice/Opt-Out
Steps to create a Privacy Notice from template:
- Select “Use Template”
- Read and review the Privacy Notice to ensure it meets your needs
- Review with your legal counsel as needed
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Download a published copy (for back-up, historical documentation, and possible distribution)
- Note: you must click both Complete and Publish in order to use the Policy
Use my own content
The “Use my own content” option provides you with the same notice as used in the Template Notice, which you will then modify to meet your legal and organizational needs. It contains the same sections provided in “Use template” (above). You may add, delete and change these sections.
Remember: a notice that is published from the “Use my own content” option will not generate a new draft of dynamic content updates when changes are made to other sections that filter through to the Privacy Notice.
Steps to create a Privacy Notice using your own content:
- Select “Use my own content”
- Modify the Privacy Notice template to meet your needs
- Review with your legal counsel as needed
- From this screen, there is not an option to do a Save. Your input is saved automatically.
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Download a published copy (for back-up, historical documentation, and possible distribution)
- Note: you must click both Complete and Publish in order to use the Policy
WARNING: Caution if changing creation method – Once you have modified the initial template provided, do not click on the other creation options (“Use template” or “Use my own document”) unless you intend to delete all of your custom changes. You will not be able to recover your modifications if you change your mind.
Use my own document
The “Use my own document” option does not allow for any text input. Instead you will choose “Upload your own document” and that notice will be stored in DPDx.
Remember: a notice that is published from the “Use my own document” option will not generate a new draft of dynamic content updates when changes are made to other sections that filter through to the Privacy Notice.
Steps to create a Privacy Notice using your own document:
- Externally create your Privacy Notice
- Review with your legal counsel as needed
- Save your document as a PDF
- Select “Upload your own document” and upload the PDF
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Note: you must click both Complete and Publish in order to use the Policy
WARNING: Caution if changing creation method – Once you have uploaded your own document, do not click on the other creation options (“Use template” or “Use my own content”) unless you intend to delete your custom document. You will not be able to recover your modifications if you change your mind, although you can change back to “Use my own document” and upload the same document again.
Integration tab (Display notice)
The Integration tab allows you to use custom HTML code in order to display your Privacy Notice on web pages where personal information is collected. You may copy the code to any of your websites where you wish to display your Privacy Notice. This code is functional only after your notice is both Completed and Published.
First, add all the domains where you wish to display the notice. Note that the list of domains is shared among Governance>Privacy Notice, Governance>Employee Privacy Notice, and Subject Access>Integration. Any requests not originating from one of the domains in this list will be rejected. To add a domain, select “Add New”.
In the pop-up, type in your domain name, and click “Save”.
Second, provide your web developers with the code to include on your web pages. You may use the “Copy Code” shortcut and paste into your message to developers. Also include the instructions just above the code regarding the Element ID.
To view how your notice will look as a web page, use the Preview option.
Edit a notice
We recommend that you review and publish a new Privacy Notice once or twice a year to ensure accuracy, regardless of the creation method used. This is also a good time to have a legal review of your notice.
Use template
All changes to a Template Notice are dynamic and are based on changes to these sections of DPDx: Organization Setup, Data Mapping, Service Providers, and Third Parties. When you make these changes, a new Draft of your Privacy Notice is automatically created to include these changes.
Use the “Download” function for both the Draft and the Published versions to compare the changes.
We recommend that you change the downloaded file name to include “draft” or “published” to differentiate each version. Review the changes based on where you have made changes in the DPDx sections that filter through to the Privacy Notice.
Click “Publish”; note the last published date will change.
When you view the Privacy Notice on your website, the HTML code renders the new version. Don’t forget to download the latest published version for your archives.
Use my own content
It is important to remember that changes in any of the sections that filter through to the Privacy Notice (Organization Setup, Data Mapping, Service Providers, and Third Parties) will not automatically update in a notice based on your own content. You need to manually make the relevant changes to the Privacy Notice after making those types of changes.
Use the “Download” function for both the Draft and the Published versions to compare the changes.
We recommend that you change the downloaded file name to include “draft” or “published” to differentiate each version.
Click “Publish”; note the last published date will change.
When you view the Privacy Notice on your website, the HTML code renders the new version. Don’t forget to download the latest published version for your archives.
WARNING: Caution if changing creation method – If you will continue using your own content, do not click “Use template” as a means of generating new dynamic content. All of your custom changes within “Use my own content” will be lost and cannot be recovered.
Use my own document
It is important to remember that changes in any of the sections that filter through to the Privacy Notice (Organization Setup, Data Mapping, Service Providers, and Third Parties) will not automatically update in a notice based on your own document. Since your own document is not directly integrated with DPDx, make changes to the document in your usual method.
When your updates are complete, click “Upload your own document” and upload the PDF.
Click “Publish”; note the last published date will change.
When you view the Privacy Notice on your website, the HTML code renders the new version.
Change notice creation method
The Privacy Notices tab will always open into the current method of notice creation. You can change your notice creation method, even if you are published. But as soon as you choose a different method, your published notice is removed. Before you begin, we recommend that you download the current version of your Privacy Notice.
WARNING: If you change away from “Use my own content” or “Use my own document”, all existing edited or uploaded content will be deleted and cannot be recovered.
Note: If you change away from “Use template”, you will no longer receive dynamic drafts with updates based on changes to sections that filter through to Privacy Notices.
To change methods, click on one of the other two available methods. If you are moving away from custom content, a warning pop-up appears. Click OK to continue.
Your previously-published Privacy Notice is removed with this action. Follow the steps in the appropriate method in “Create Privacy Notice” above. Change the Status to “Not started” or “In progress” if appropriate.
Delete a notice
Before you begin a deletion, we recommend that you download the current version of your Privacy Notice.
To delete a Notice, change your notice creation method. Doing so removes the current draft and published versions for that method.
Example:
Current notice = “Use my own content”
Choose “Use template” and click “OK” on the pop-up to confirm deletion of content. You will see that this method has no published Privacy Notice.
Return to “Use my own content”. You will see it has been cleared of content.
If you will create a new notice, follow the steps in the appropriate method in “Create Privacy Notice” above. Change the Status to “Not started”, “In progress”, or N/A if appropriate.
Note: For the “Use my own document” method, you may also choose “Delete” to the right of the uploaded document listing. This method leaves the Notice as Published, even though there is no corresponding document.
Download a notice
As you publish your Privacy Notice, we recommend that you download copies for backup and historical documentation.
“Use template” and “Use my own content” – use the Download button
- Prior to Publishing, you may download a draft
- After Publishing, you may download both draft and published versions
“Use my own document” – click on the uploaded document name, then use your browser’s download function.
Employee Privacy Notice
Your Employee Privacy Notice should be regularly shared with employees, and they should be given the opportunity to acknowledge its contents. This Employee Privacy Notice should be displayed wherever you collect personal information.
When you enter the Employee Privacy Notice section, you may dismiss the introduction by clicking the “X”. The page begins with section tabs, and also displays your auto-generated Employee Privacy Notice.
Employee Privacy Notice tab
You must begin in the “Employee Privacy Notice” creation tab. You cannot use the “Integration” tab until your notice is “Published”.
The Employee Privacy Notice tab shows content creation options and document status information.
If your organization will not use this Employee Privacy Notice, choose Status = N/A.
Create Employee Privacy Notice
The first step is to choose your creation method:
- Use template: uses a provided template; content cannot be changed
- Use my own content: begins with a provided template; then you modify content
- Use my own document: you upload a document which contains your custom content
If you are not sure which method to use, we recommend that you “Use template” and consult with your legal counsel.
WARNING: Caution if changing creation method – After you choose a content creation method, use extreme caution if you decide to change methods. Changing methods will cause all edited or uploaded content to be deleted and it cannot be recovered. There is a pop-up reminder where you must confirm your choice. If you change methods we recommend that you download a copy of your existing version before clicking the new option.
Use template
DPDx provides a template of an Employee Privacy Notice with essential elements informed by US regulation. Additionally, custom content is drawn from these sections in DPDx: Organization Setup, Data Mapping, Service Providers, and Third Parties.
When you make changes to the DPDx sections that filter through to the Employee Privacy Notice, the Draft version of your Template Notice will also be updated dynamically to show these changes. See the section below, Edit a notice, for instructions on Publishing the updated notice.
You cannot make any changes to the text in a Template Notice.
The following sections are included in the template:
- Why do we need your personal information?
- What personal information do we collect?
- Sensitive data
- Change of purpose
- Third Parties
- How do we look after personal information?
- Your Rights
- Right to withdraw consent
- Our Organization
Steps to create an Employee Privacy Notice from template:
- Select “Use Template”
- Read and review the Employee Privacy Notice to ensure it meets your needs
- Review with your legal counsel as needed
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Download a published copy (for back-up, historical documentation, and possible distribution)
- Note: you must click both Complete and Publish in order to use the Policy
Use my own content
The “Use my own content” option provides you with the same notice as used in the Template Notice, which you will then modify to meet your legal and organizational needs. It contains the same sections provided in “Use template” (above). You may add, delete and change these sections.
Remember: a notice that is published from the “Use my own content” option will not generate a new draft of dynamic content updates when changes are made to other sections that filter through to the Employee Privacy Notice.
Steps to create an Employee Privacy Notice using your own content:
- Select “Use my own content”
- Modify the Employee Privacy Notice template to meet your needs
- Review with your legal counsel as needed
- From this screen, there is not an option to do a Save. Your input is saved automatically.
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Download a published copy (for back-up, historical documentation, and possible distribution)
- Note: you must click both Complete and Publish in order to use the Policy
WARNING: Caution if changing creation method – Once you have modified the initial template provided, do not click on the other creation options (“Use template” or “Use my own document”) unless you intend to delete all of your custom changes. You will not be able to recover your modifications if you change your mind.
Use my own document
The “Use my own document” option does not allow for any text input. Instead you will choose “Upload your own document” and that notice will be stored in DPDx.
Remember: a notice that is published from the “Use my own document” option will not generate a new draft of dynamic content updates when changes are made to other sections that filter through to the Employee Privacy Notice.
Steps to create an Employee Privacy Notice using your own document:
- Externally create your Employee Privacy Notice
- Review with your legal counsel as needed
- Save your document as a PDF
- Select “Upload your own document” and upload the PDF
- Select status “Completed”
- Select “Publish”
- “Last published” information is automatically updated
- Note: you must click both Complete and Publish in order to use the Policy
WARNING: Caution if changing creation method – Once you have uploaded your own document, do not click on the other creation options (“Use template” or “Use my own content”) unless you intend to delete your custom document. You will not be able to recover your modifications if you change your mind, although you can change back to “Use my own document” and upload the same document again.
Integration tab (Display notice)
The Integration tab allows you to use custom HTML code in order to display your Employee Privacy Notice on web pages where personal information is collected. You may copy the code to any of your websites where you wish to display your Employee Privacy Notice. This code is functional only after your notice is both Completed and Published.
First you must configure additional domains, if needed. Note that the list of domains is shared among Governance>Privacy Notice, Governance>Employee Privacy Notice, and Subject Access>Integration. Any requests not originating from one of the domains in this list will be rejected. If you need to add a different domain for your Employee Privacy Notice, select “Add New”.
In the pop-up, type in your domain name, and click “Save”.
Second, provide your web developers with the code to include on your web pages. You may use the “Copy Code” shortcut and paste into your message to developers. Also include the instructions just above the code regarding the Element ID.
To view how your notice will look as a web page, use the Preview option.
Edit a notice
Use template
We recommend that you review and publish a new Employee Privacy Notice once or twice a year to ensure accuracy, regardless of the creation method used. This is also a good time to have a legal review of your notice.
All changes to a Template Notice are dynamic and are based on changes to these sections of DPDx: Organization Setup, Data Mapping, Service Providers, and Third Parties. When you make these changes, a new Draft of your Employee Privacy Notice is automatically created to include these changes.
Use the “Download” function for both the Draft and the Published versions to compare the changes.
We recommend that you change the downloaded file name to include “draft” or “published” to differentiate each version. Review the changes based on where you have made changes in the DPDx sections that filter through to the Employee Privacy Notice.
Click “Publish”; note the last published date will change.
When you view the Employee Privacy Notice on your website, the HTML code renders the new version. Don’t forget to download the latest published version for your archives.
Use my own content
It is important to remember that changes in any of the sections that filter through to the Employee Privacy Notice (Organization Setup, Data Mapping, Service Providers, and Third Parties) will not automatically update in a notice based on your own content. You need to manually make the relevant changes to the Employee Privacy Notice after making those types of changes.
Use the “Download” function for both the Draft and the Published versions to compare the changes.
We recommend that you change the downloaded file name to include “draft” or “published” to differentiate each version.
Click “Publish”; note the last published date will change.
When you view the Employee Privacy Notice on your website, the HTML code renders the new version. Don’t forget to download the latest published version for your archives.
WARNING: Caution if changing creation method – If you will continue using your own content, do not click “Use template” as a means of generating new dynamic content. All of your custom changes within “Use my own content” will be lost and cannot be recovered.
Use my own document
It is important to remember that changes in any of the sections that filter through to the Employee Privacy Notice (Organization Setup, Data Mapping, Service Providers, and Third Parties) will not automatically update in a notice based on your own document. Since your own document is not directly integrated with DPDx, make changes to the document in your usual method.
When your updates are complete, click “Upload your own document” and upload the PDF.
Click “Publish”; note the last published date will change.
When you view the Employee Privacy Notice on your website, the HTML code renders the new version.
Change notice creation method
The Employee Privacy Notices tab will always open into the current method of notice creation. You can change your notice creation method, even if you are published. But as soon as you choose a different method, your published notice is removed. Before you begin, we recommend that you download the current version of your Employee Privacy Notice.
WARNING: If you change away from “Use my own content” or “Use my own document”, all existing edited or uploaded content will be deleted and cannot be recovered.
Note: If you change away from “Use template”, you will no longer receive dynamic drafts with updates based on changes to sections that filter through to Employee Privacy Notices.
To change methods, click on one of the other two available methods. If you are moving away from custom content, a warning pop-up appears. Click OK to continue.
Your previously-published Employee Privacy Notice is removed with this action. Follow the steps in the appropriate method in “Create Employee Privacy Notice” above. Change the Status to “Not started” or “In progress” if appropriate.
Delete a notice
Before you begin a deletion, we recommend that you download the current version of your Employee Privacy Notice.
To delete a Notice, change your notice creation method. Doing so removes the current draft and published versions.
Example:
Current notice = “Use my own content”
Choose “Use template” and click “OK” on the pop-up to confirm deletion of content. You will see that this method has no published Employee Privacy Notice.
You may also return to “Use my own content” which has been cleared of content.
If you will create a new notice, follow the steps in the appropriate method in “Create Employee Privacy Notice” above. Change the Status to “Not started”, “In progress”, or N/A if appropriate.
Note: For the “Use my own document” method, you may also choose “Delete” to the right of the uploaded document listing. This method leaves the Notice as Published, even though there is no corresponding document.
Download a notice
As you publish your Employee Privacy Notice, we recommend that you download copies for backup and historical documentation.
“Use template” and “Use my own content” – use the Download button
- Prior to Publishing, you may download a draft
- After Publishing, you may download both draft and published versions
“Use my own document” – click on the uploaded document name
Once you have completed both privacy notices you are ready for the next section. Click the tab to the right of “Privacy notices”, which is “Internal”.
