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Data Processor Privacy Notice Template for Netherlands

A comprehensive privacy notice document governed by Dutch law and compliant with the EU General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG). This notice outlines how an organization, acting as a data processor, handles personal data on behalf of data controllers, including the types of data processed, processing purposes, security measures, data subject rights, and international transfer protocols. The document serves as a transparency tool ensuring compliance with Dutch and EU data protection requirements while providing clear information to data subjects about how their personal data is processed.

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What is a Data Processor Privacy Notice?

The Data Processor Privacy Notice is a crucial document required under Dutch data protection law and the EU GDPR framework. It should be implemented when an organization acts as a data processor, handling personal data on behalf of data controllers. This notice fulfills the transparency obligations under Articles 13 and 14 of the GDPR, as well as specific requirements under the Dutch GDPR Implementation Act (UAVG). The document must be provided to data subjects whose personal data is being processed and should be easily accessible, typically through the processor's website or other communication channels. It needs regular updates to reflect any changes in processing activities, organizational structure, or legal requirements.

What sections should be included in a Data Processor Privacy Notice?

1. Identity and Contact Details: Information about the data processor, including company name, registration details, and contact information including DPO details if applicable

2. Types of Personal Data Processed: Clear list and explanation of the categories of personal data that are processed

3. Processing Activities and Purposes: Detailed explanation of how and why personal data is processed, including the legal bases for processing

4. Data Retention: Information about how long personal data is kept and the criteria used to determine retention periods

5. Data Security: Overview of security measures implemented to protect personal data

6. Data Subject Rights: Explanation of individual rights under GDPR and how to exercise them

7. International Transfers: Information about any transfers of personal data outside the EEA and safeguards in place

8. Updates to This Notice: Information about how changes to the privacy notice will be communicated

What sections are optional to include in a Data Processor Privacy Notice?

1. Automated Decision Making: Required when automated decision-making or profiling is performed, explaining the logic involved and significance of such processing

2. Children's Privacy: Required when services may be accessed by or data collected from children, explaining special protections and parental consent requirements

3. Cookies and Tracking Technologies: Required when the processor uses cookies or similar tracking technologies

4. Special Categories of Personal Data: Required when processing special categories of personal data (sensitive data), explaining additional safeguards

What schedules should be included in a Data Processor Privacy Notice?

1. Schedule 1: Detailed Processing Activities: Comprehensive list of specific processing activities, including purposes, categories of data, and retention periods

2. Schedule 2: Technical and Organizational Security Measures: Detailed description of security measures implemented to protect personal data

3. Schedule 3: Sub-processors: List of sub-processors used, including their locations and roles

4. Schedule 4: Data Transfer Mechanisms: Detailed information about international transfer mechanisms and safeguards

Authors

Alex Denne

Head of Growth (Open Source Law) @ 黑料视频 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents

Jurisdiction

Netherlands

Publisher

黑料视频

Document Type

Privacy Notice

Cost

Free to use

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