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Just In Time Privacy Notice Template for England and Wales

A Just In Time Privacy Notice is a concise, context-specific notification provided to users at the exact moment their personal data is being collected. Under English and Welsh law, particularly the UK GDPR and Data Protection Act 2018, these notices serve as transparent, immediate explanations of data processing activities. They are designed to provide relevant information about data collection and processing in a clear, accessible format at the point of collection, rather than buried within a longer privacy policy.

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What is a Just In Time Privacy Notice?

Just In Time Privacy Notices have become increasingly important in the UK's data protection landscape as organizations seek to enhance transparency and build trust with their users. These notices, required under English and Welsh law, provide immediate, relevant information about specific data processing activities at the exact moment of collection. They supplement broader privacy policies by offering context-specific information when users are most likely to read and understand it. The Just In Time Privacy Notice should explain what data is being collected, why it's needed, how it will be used, and any relevant rights the individual has regarding that specific processing activity.

What sections should be included in a Just In Time Privacy Notice?

1. Data Controller Identity: Name and contact details of the organization collecting the data, including the Data Protection Officer's contact information where applicable

2. Purpose of Processing: Clear explanation of why this specific piece of data is being collected and how it will be used

3. Legal Basis: Explanation of the specific legal ground under UK GDPR for processing this particular data

4. Data Retention: Information about how long this specific piece of data will be kept and why

5. Your Rights: Brief overview of the relevant data subject rights for this specific processing activity

What sections are optional to include in a Just In Time Privacy Notice?

1. International Transfers: Information about transfers of data outside the UK, including safeguards in place - include when data will be transferred internationally

2. Automated Decision Making: Details about any automated processing or profiling - include when automated decision-making is involved

3. Third Party Sharing: Information about other organizations the data will be shared with - include when data will be shared with third parties

4. Special Category Data: Additional information about processing of sensitive data - include when collecting special category data

What schedules should be included in a Just In Time Privacy Notice?

1. Cookie List: Detailed list of cookies and similar technologies used in relation to this specific data collection

2. Processing Activities: Detailed breakdown of specific processing activities related to this data collection

3. Third Party Processors: List of data processors involved in this specific processing activity and their roles

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok成人版 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents

Jurisdiction

England and Wales

Document Type

Privacy Notice

Cost

Free to use

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