Privacy Information Notice Template for United Arab Emirates

A Privacy Information Notice drafted under UAE law, specifically compliant with Federal Decree-Law No. 45/2021 and its Executive Regulations, is a comprehensive document that informs individuals about how their personal data is collected, processed, and protected. This document serves as a mandatory transparency tool that details the organization's data processing activities, legal bases for processing, data subject rights, and security measures implemented. The notice must align with UAE's data protection framework, including specific requirements for organizations operating in free zones such as DIFC and ADGM where applicable, and should be regularly updated to reflect any changes in data processing practices or regulatory requirements.

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What is a Privacy Information Notice?

The Privacy Information Notice is a fundamental document required under UAE Federal Decree-Law No. 45/2021 and its Executive Regulations, designed to ensure transparency in data processing activities. This document should be implemented by any organization that collects and processes personal data in the UAE, whether for commercial, professional, or other purposes. The Privacy Information Notice must detail the types of personal data collected, purposes of processing, data subject rights, security measures, and data retention periods. It serves as a critical compliance tool, particularly important given the UAE's enhanced focus on data protection through its comprehensive federal data protection law. Organizations must ensure their notice is easily accessible, written in clear language, and regularly updated to reflect current data processing practices and regulatory requirements.

What sections should be included in a Privacy Information Notice?

1. Introduction: Overview of the notice's purpose and scope, including the identity of the data controller

2. Definitions: Key terms used throughout the notice, aligned with UAE Federal Decree-Law No. 45/2021 terminology

3. Types of Personal Data Collected: Comprehensive list of personal data categories collected and processed

4. Legal Basis for Processing: Explanation of the legal grounds for data processing under UAE law

5. Purposes of Processing: Detailed description of how and why personal data is processed

6. Data Subject Rights: Explanation of individual rights under UAE law, including access, correction, and deletion rights

7. Data Security Measures: Overview of technical and organizational measures to protect personal data

8. Data Retention: Information about how long personal data is kept and criteria for retention periods

9. Contact Information: Details for contacting the organization regarding privacy matters

10. Updates to this Notice: Information about how changes to the notice will be communicated

What sections are optional to include in a Privacy Information Notice?

1. International Data Transfers: Required if personal data is transferred outside the UAE, detailing transfer mechanisms and safeguards

2. Automated Decision Making: Required if the organization uses automated processing to make decisions about individuals

3. Cookies and Tracking Technologies: Required for organizations operating websites or apps that use tracking technologies

4. Children's Privacy: Required if services are offered to or may collect data from children

5. Special Categories of Data: Required if processing sensitive personal data as defined in UAE law

6. Third-Party Data Sharing: Required if personal data is shared with external parties or service providers

7. Free Zone Specific Provisions: Required if operating in DIFC or ADGM, addressing additional requirements of these jurisdictions

What schedules should be included in a Privacy Information Notice?

1. Data Categories and Processing Purposes Matrix: Detailed matrix showing specific data types collected and their corresponding processing purposes

2. Third-Party Recipients List: List of categories of third parties with whom data is shared, if applicable

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

4. Data Retention Schedule: Specific retention periods for different categories of personal data

5. Cookie List: Detailed list of cookies and similar technologies used, if applicable

Authors

Alex Denne

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

Cost

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