Privacy policy covers all data types, purposes, retention, third-parties, user rights
Why it matters
GDPR Art. 13 and Art. 14 require controllers to provide data subjects with specific information at the point of collection, including retention periods, third-party recipients, legal basis for each processing purpose, and a description of user rights. CCPA §1798.100 and LGPD Art. 9 impose equivalent disclosure obligations for US and Brazilian users respectively. An incomplete or missing privacy policy is not a minor oversight — it is a standalone regulatory violation independent of any breach. Regulators in the EU, UK, and California treat absent or skeletal policies as evidence of systemic non-compliance, which increases penalties. ISO-27001:2022 A.5.34 requires that privacy notice obligations be documented and fulfilled.
Severity rationale
High because an absent or incomplete privacy policy is itself a regulatory violation under GDPR Art. 13, independent of any actual data misuse, and undermines user trust across the entire product.
Remediation
Draft a policy that covers all seven required sections. A privacy policy generator (Iubenda, Termly) can scaffold the structure — customize it to match your actual data flows. Add a footer link to it on every page.
Required sections your policy must include:
1. Data collected — email, name, payment info, usage events, cookies
2. Purpose for each — contract/service delivery, analytics, marketing
3. Retention periods — account data: until deletion; analytics: 26 months; logs: 90 days
4. Third-party recipients — Stripe (payments), SendGrid (email), GA4 (analytics); include DPA links
5. User rights — access, deletion, correction, portability, opt-out of marketing
6. Legal basis — contract for service delivery; consent for newsletters; legitimate interest for fraud
7. Privacy contact — privacy@example.com or a web form
Link the policy in your root layout's footer so it appears on every page without authentication. Update within 30 days whenever you add a new third-party service or change a data handling practice.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the Data Protection Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- gdpr · Art. 13 — Information to be provided where personal data are collected from the data subject
- gdpr · Art. 14 — Information to be provided where personal data have not been obtained from the data subject
- ccpa · §1798.100 — Consumer right to know about personal information collected
- lgpd · Art. 9 — Right to access and privacy notice requirements
- iso-27001:2022 · A.5.34 — Privacy and protection of PII
Taxons
History
- 2026-04-18·v1.0.0·Initial import from data-protection·automated