The document should include a section called “Procedure and Conditions for Processing Personal Data.” It should list all the actions your company will perform with the collected information about individuals. As well as the timeframes during which these actions will be performed. And, of course, the methods you will use in the processing process. This may be the direct collection of information, its systematization, recording, accumulation and storage. This also includes clarification of the collected information, making additions and changes, their use, extraction, distribution and provision of access to them. Plus blocking, depersonalization, complete deletion or destruction of personal information. When you draw up a privacy policy for your own website, list exactly those actions that your company will perform. Although it is more common to indicate all possible ways of working with the user's personal data.
Different methods of collecting personal information have different legal consequences. Therefore, it is necessary to indicate the method that you are going to use. This can be automated or non-automated collection of information. In the second case, all actions are performed manually. And in the first case, with the help of computer technology.
The processing periods for each category of subjects must be clearly defined and delineated.
The date of termination of the processing of personal data is considered to have occurred if one of the events listed below has occurred:
the originally stated goals of collecting and processing information have already been achieved;
the period for which the subject gave bank email list his consent for the processing of his personal data has expired. Or the person has revoked this consent before the agreed period;
it was revealed that one of the methods of processing personal data was unlawful;
There are many recommendations here, but they are not completely exhaustive. In general, it is always necessary to approach the creation of a privacy policy for a website meticulously and step by step. First, structure the process of processing the collected data (the participation of an information security specialist is necessary here).
Then, work out and form the text of the document, where all actions that will be performed with the personal information collected about users are specifically described. And after that, publish the document and begin processing the data in accordance with the provisions specified in it. The list of actions performed with respect to the information collected about the user includes backup copying, and responding to requests, and responding to possible disagreements.
It is best to involve lawyers specializing in IT law in writing the privacy policy. Because the result of independently drafting this document may be fines from Roskomnadzor, the amounts of which are often much higher than the cost of paying for the services of professionals.
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