Q&As

Do I have to send my new or updated privacy policy to former clients?

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Published on LexisPSL on 04/06/2018

The following Risk & Compliance Q&A provides comprehensive and up to date legal information covering:

  • Do I have to send my new or updated privacy policy to former clients?

If you hold personal data of former clients, then you will be processing it for the purposes of the General Data Protection Regulation, Regulation (EU) 2016/679 (the GDPR) (as processing includes the storage of data in accordance to Article 4(2) of Retained Regulation (EU) 2016/679).

The GDPR contains extensive information requirements. See Practice Note: Privacy notices—information requirements and Precedent: Privacy notice audit.

You do not have to provide further information to former clients if they already have it. You should therefore consider, in the light of t

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