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Layered Privacy Notice
"I need a Layered Privacy Notice for a Swiss fintech startup that processes customer payment data and integrates with multiple banking partners, with a planned launch date of March 2025 - it must comply with both FADP and include GDPR-aligned provisions as we plan to expand to EU markets."
1. Layer 1 - Brief Overview: A concise summary of key privacy information, including identity of data controller, purposes of processing, and data subject rights
2. Layer 2 - Detailed Privacy Notice: Comprehensive information about data processing activities
3. Who We Are: Identity and contact details of the data controller and, where applicable, representative and Data Protection Officer
4. Personal Data We Collect: Categories of personal data collected and processed
5. How We Use Your Data: Purposes and legal bases for processing personal data
6. Data Sharing and Recipients: Information about third parties who receive personal data
7. International Transfers: Details about data transfers outside Switzerland/EEA and safeguards
8. Data Retention: How long personal data is kept and criteria for retention periods
9. Your Privacy Rights: Explanation of data subject rights under Swiss law and how to exercise them
10. Security Measures: Overview of technical and organizational measures to protect personal data
11. Updates to This Notice: Information about how changes to the privacy notice will be communicated
1. Automated Decision-Making: Required when automated decision-making or profiling is used
2. Cookie Information: Required when cookies or similar technologies are used on websites
3. Children's Privacy: Required when services may be used by or data collected from children
4. Direct Marketing: Required when personal data is used for direct marketing purposes
5. Industry-Specific Disclosures: Required for regulated industries like banking or healthcare
6. Employment Data Processing: Required when notice covers employee data processing
7. CCTV and Surveillance: Required when video surveillance or monitoring systems are used
8. Special Categories of Data: Required when processing sensitive personal data
1. Data Processing Activities: Detailed inventory of specific data processing activities and their characteristics
2. Technical and Organizational Measures: Detailed description of security measures implemented
3. Subprocessor List: List of third-party data processors and their roles
4. Cookie List: Detailed list of cookies used, including purposes and duration
5. Privacy Rights Request Form: Template form for submitting data subject rights requests
6. Record of Updates: Log of changes made to the privacy notice over time
Authors
Financial Services
Healthcare
Technology
Retail
Manufacturing
Education
Professional Services
Telecommunications
Insurance
Real Estate
Hospitality
E-commerce
Non-profit Organizations
Public Sector
Transportation and Logistics
Legal
Compliance
Privacy
Information Security
Risk Management
Information Technology
Marketing
Human Resources
Customer Service
Data Protection
Internal Audit
Corporate Communications
Operations
Digital
Information Governance
Data Protection Officer
Privacy Manager
Compliance Officer
Legal Counsel
Information Security Manager
Risk Manager
Chief Privacy Officer
Chief Legal Officer
Chief Compliance Officer
Chief Information Security Officer
Privacy Analyst
Compliance Manager
Data Protection Specialist
Privacy Counsel
Information Governance Manager
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