Manual mechanisms to draft and update privacy notices in line with regulatory requirements are costly, lengthy, inefficient, and risky endeavors for organizations. This is because:
All organizations are constantly updating or changing the purposes for which they collect, process, share, sell or retain the personal data of data subjects, and thus, being able to update these details within the privacy notice in real-time becomes an issue of coordination and management;
Many SMEs lack the expertise of drafting privacy notices quickly according to regulatory requirements and must hire expensive legal specialists. This makes it difficult for SMEs to continually update their privacy notices as the use of personal data continues to evolve;
Privacy notices need to be updated and require inputs from various teams within an organization. Thus, keeping track of different versions, the changes, and updates made to the notice become difficult;
Larger organizations sometimes need to centrally manage privacy notices for all their departments or business units, each with its own unique set of data processing activities. This is a time-consuming and tedious process, especially since every department or business unit’s personal data collection and processing requirements can undergo rapid changes. This makes it impossible for large organizations to update multiple privacy policies using manual review mechanisms;
For organizations utilizing agile development, data processing changes can cause privacy notices to be out of date very quickly. This is especially true for the use of cookies within the website environment. Suppose privacy officers cannot track changes/updates in data processed, collected, sold, shared, or retained by the organization. In that case, they may develop inaccurate or incomplete notices causing privacy violations & increasing the risk of potential fines and lawsuits.
Organizations working within multiple jurisdictions need to read and analyze different global laws and regulations and ascertain requirements for privacy notices for each region. They then must include these details either geo-specifically or universally within the privacy notice to stay compliant. This is a huge endeavor requiring specialist legal knowledge.
The legal and regulatory is ever-shifting and new regulations and amendments to existing regulations are commonplace. This requires constant vigilance and the capability to bring changes and updates to the information presented within the privacy notice.
