Just in Time Privacy Notice for GDPR Compliance
The United Kingdom Information Commissioner’s Office has endorsed the use of the just in time notice as part of its code of practice for a clear and effective privacy notice. The ICO rejects the idea that a single privacy disclosure is the right method for informing individuals about the collection and usage of personal data in every situation. Instead, it believes that a blended approach that uses a combination of techniques can better deliver information
Just in time privacy notices improve transparency and build consumer trust by providing individuals information about data collection, usage and sharing at the time that it is needed by the individual to make an informed decision. It does not rely on obtaining consent through a disclosure months earlier that the user may or may not have read and comprehended.
The just-in-time concept was developed and popularized in manufacturing and inventory in order to increase efficiency and decrease waste. It aims to ensure that parts in the manufacturing process are supplied shortly before they are needed so that they do not have to have extensive inventory stocks.
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The General Data Protection Regulation requires that organizations offer transparency about their data collection, usage and sharing. It requires privacy disclosures that are concise, intelligible and in plain English. One way to accomplish the requirement of GDPR Article 12 on transparency is through a just in time notice.
In order to fulfill the transparency requirement, the GDPR mandates businesses provide users with a fair amount of information as part of its disclosures. One way to accomplish this mission without overwhelming users is through layered privacy disclosures that include just in time notices. The ICO says, “A layered approach can be useful as it allows you to provide the key privacy information immediately and have more detailed information available elsewhere for those that want it.”
The ICO further explains that, “Just-in-time notices work by appearing on the individual’s screen at the point where they input personal data, providing a brief message explaining how the information they are about to provide will be used.”
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