Practice 3 minutes read

A privacy notice somebody can actually read

The Regulation demands a "concise, transparent, intelligible and easily accessible form, using clear and plain language". The usual generated text meets none of those four – and is therefore a breach in its own right.

The duty to inform is not a boilerplate block but a piece of information. It should let a person understand what happens to their data – and then decide whether they are comfortable with it. A text nobody reads to the end has missed that purpose, however complete it may be.

The mandatory content

  • Who the controller is – with contact details, and those of the data protection officer where one exists.
  • Which purposes are pursued – individually, not as a list of possibilities.
  • On which legal basis – named per purpose. For legitimate interests, additionally which interest.
  • Who receives the data – recipients or at least categories, and the actual names on request.
  • For how long data is kept – or the criteria determining the period.
  • Which rights exist – including withdrawal, objection and complaint to the supervisory authority.
  • Whether transfers to third countries take place and on what basis.
  • Whether providing data is required and what follows from not doing so.

The structure makes the difference

Two structures for the same content

Structured by legal provision
Structured by situation
"Legal bases of processing"
"When visiting this website"
"Recipients and categories of recipients"
"When submitting the contact form"
"Duration of storage"
"When placing an order"
Complete, but has to be read across to answer any one question
Equally complete, but each question is answered in one place

The most common defects

  • Services that are not used. A generated text names providers that do not exist on this site – and may omit the ones that do.
  • Legal bases in the conditional. "Processing may rest on Article 6(1)(a), (b) or (f)" is not information but a list.
  • Missing retention periods. "As long as necessary" merely repeats the statute instead of filling it in.
  • An outdated state. The text is written once and never touched again – while the embedded services keep changing.

Against the last point a simple rule helps: the text gets touched whenever a service is added or removed – in the same work step, not a later one. Anyone adopting that needs no annual review, because the notice never falls out of date.

Published 2 October 2026

This article explains general principles and does not replace legal advice on an individual case.

Back to the overview