The Data Privacy Notice serves as a fundamental document required under UAE Federal Decree Law No. 45/2021, designed to inform data subjects about how their personal data is collected, processed, and protected. Organizations operating in the UAE must maintain transparency in their data processing activities through this notice, which needs to comply with both federal requirements and, where applicable, specific free zone regulations such as DIFC and ADGM data protection laws. The document should be implemented when an organization collects or processes personal data, requiring regular updates to reflect changes in data processing activities or regulatory requirements. It forms a crucial part of an organization's data protection framework and demonstrates compliance with UAE privacy laws.
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1. Introduction: Overview of the organization and the purpose of the privacy notice
2. Scope and Application: Who the privacy notice applies to and what activities it covers
3. Definitions: Key terms used throughout the notice, aligned with UAE law definitions
4. Data Controller Information: Identity and contact details of the data controller and, where applicable, their representative
5. Types of Personal Data Collected: Detailed categories of personal data collected and processed
6. Purposes of Processing: Specific purposes for which personal data is collected and processed
7. Legal Basis for Processing: Legal grounds under UAE law for processing personal data
8. Data Sharing and Recipients: Categories of third parties with whom data is shared
9. Data Security Measures: Overview of technical and organizational measures to protect personal data
10. Data Retention: How long different types of personal data are retained
11. Individual Rights: Rights of data subjects under UAE law and how to exercise them
12. Updates to Privacy Notice: How and when changes to the privacy notice will be communicated
13. Contact Information: How to contact the organization for privacy-related queries
1. International Data Transfers: Include when personal data is transferred outside the UAE, describing transfer mechanisms and safeguards
2. Automated Decision Making: Include when automated processing, including profiling, is used to make decisions about individuals
3. Cookies and Tracking Technologies: Include for web-based services that use cookies or similar tracking technologies
4. Children's Privacy: Include when services may involve processing children's personal data
5. Special Categories of Data: Include when processing sensitive personal data such as health information or biometric data
6. Data Protection Officer: Include when the organization has appointed a Data Protection Officer
7. Free Zone Specific Provisions: Include when operating in DIFC, ADGM or other free zones with specific data protection requirements
1. Schedule 1: Detailed Data Categories: Comprehensive list of all personal data categories collected and processed
2. Schedule 2: Third Party Recipients: Detailed list of third-party data recipients and processors
3. Schedule 3: Technical Security Measures: Detailed description of security measures and safeguards implemented
4. Schedule 4: Data Retention Schedule: Detailed retention periods for different categories of personal data
5. Schedule 5: Cookie Policy: Detailed information about cookies and other tracking technologies used
6. Schedule 6: Processing Activities Register: Detailed register of processing activities as required by UAE law
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