The External Privacy Notice is a mandatory document under Swiss data protection law that organizations must provide to individuals whose personal data they process. This document has gained increased importance with the implementation of the revised Swiss Federal Data Protection Act (FADP/DSG) in 2023, which brought Swiss privacy requirements closer to GDPR standards. The External Privacy Notice must be easily accessible, written in clear language, and detail all aspects of an organization's data processing activities, including the types of data collected, processing purposes, data sharing practices, and data subject rights. It serves as both a compliance tool and a trust-building mechanism with stakeholders, requiring regular updates to reflect changes in data processing practices or legal requirements.
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1. Introduction: Overview of the privacy notice and its scope, including the identity and contact details of the data controller
2. Key Terms and Definitions: Explanation of important terms used throughout the privacy notice
3. Types of Personal Data We Collect: Detailed categorization of personal data collected, including special categories if applicable
4. How We Collect Your Personal Data: Description of data collection methods and sources
5. Purposes and Legal Bases for Processing: Explanation of why personal data is processed and the legal grounds for processing
6. Data Sharing and Recipients: Information about third parties with whom data is shared
7. International Data Transfers: Details about cross-border data transfers and safeguards
8. Data Retention: Information about how long personal data is kept
9. Your Privacy Rights: Description of data subject rights under Swiss law and how to exercise them
10. Data Security: Overview of security measures protecting personal data
11. Changes to This Privacy Notice: Information about how changes to the privacy notice will be communicated
12. Contact Information: Details for the data protection officer or privacy contact person
1. Cookies and Tracking Technologies: Required if the organization uses cookies or similar tracking technologies on websites
2. Marketing Communications: Required if personal data is used for direct marketing purposes
3. Automated Decision Making: Required if the organization uses automated decision-making or profiling
4. Children's Privacy: Required if services might be accessed by or data collected from minors
5. Employment-Related Data Processing: Required if the privacy notice covers job applicants or employees
6. Special Categories of Personal Data: Required if processing sensitive personal data such as health information
7. Specific Processing Activities: Required for unique or complex processing operations specific to the organization
1. Cookie List: Detailed list of cookies used, their purposes, and duration
2. Third-Party Processors: List of data processors and their locations
3. Technical and Organizational Measures: Detailed description of security measures implemented
4. Specific Processing Activities: Detailed information about particular processing activities that require more extensive explanation
5. Country-Specific Provisions: Additional provisions required for specific countries where the organization operates
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