Simplified Privacy Statements on Public Websites (NO0066)

Summary of the commitment

Contribute to public agencies formulating and publishing simplified and more understandable statements on the processing of personal data.

Description of the problem

1. What problems will the commitment solve? It is a challenge that many privacy statements in both the public and private sectors are difficult to access. They are both legally and technically complex, and often linguistically complicated. This makes it difficult for data subjects to understand what personal data is processed and how it is processed. The aim of the commitment is to make such declarations more user-friendly.

2. What is the cause of the problem? There is reason to believe that the concern about not providing sufficient information to fulfil the information obligations in the GDPR is the reason why many privacy statements are very complex.

Description of the commitment

1. What has been done so far to solve the problem? We are not aware of any specific efforts on the part of the authorities to contribute to simplified privacy statements. However, some work has taken place under private auspices, such as the development of icons to replace written text, but we are not aware of anyone having utilised such solutions in Norway.

2. What kind of solution is proposed? DFD, in possible cooperation with the Norwegian Data Protection Authority, DFØ and Digdir, has taken the initiative to prepare templates for privacy information/privacy statements. This will be a component of the work on the Central Government Communication Policy. The template can be utilised by the public sector as a basis for its information on the processing of personal data.

3. What results will be achieved by implementing the commitment? Simplified and more understandable information about the processing of personal data for citizens. This will be in accordance with the information obligation in GDPR Art. 12(1).

Analysis of the commitment

1. How will the commitment promote openness? More accessible and understandable information promotes openness in the public administration and helps to build trust between citizens and the public administration.

2. How will the commitment contribute to greater predictability? Understandable information shows users how public agencies take responsibility and comply with the obligations of the data protection regulations, i.e. that they handle personal data in a lawful, fair and transparent manner, as required by the regulations.

3. How will the commitment improve the opportunity for citizens to participate by publicising, implementing and monitoring the solutions?

Plan for commitment

Template for simplified and more understandable privacy statements/information about the processing of personal data on public websites.

Action Plan Review

Commitment 3. Simplified privacy statements on public websites

For Commitment 3, the Ministry of Digitization and Public Governance (DFD) aims to develop a common template for public sector websites on presenting how they process personal data. The goal is to make information about the processing of personal data more understandable for the public. However, it is unclear if the DFD intends to mandate the use of template by all public sector entities. At the midterm refresh, the DFD could take stock of the uptake of the template and discuss how to get more public institutions to adopt it. The DFD could utilize the Language Council of Norway’s Plain Language Guide for civil servants when developing the template. [26]