Keeping the public statement accurate.
WHY IT MATTERS
It is a representation, and inaccuracy is actionable.
WHAT CHANGES WITHOUT ANYONE UPDATING IT
New data collected New third parties New purposes Changed retention Changed transfers
WHAT TO CHECK IT AGAINST
The data inventory.
WHY THAT SPECIFICALLY
If they disagree, one of them is wrong.
WHAT TO VERIFY
Every category of data listed is still collected Everything collected is listed Every recipient named is still used Every new recipient is named Retention matches the schedule Transfers are accurately described
WHAT TO ALSO CHECK
Contact details are current The complaint route works Links are not broken
WHAT TO UPDATE
Anything inaccurate.
WHAT TO DO ABOUT MATERIAL CHANGES
Tell people, rather than silently amending.
HOW
A notice, proportionate to the change.
WHAT TO KEEP
Previous versions, dated.
WHY
You may need to show what someone was told when.
WHAT TO RECORD
The review, and what changed.
WHO SHOULD DO IT
Whoever holds the responsibility, with input from each team.
WHAT TO SCHEDULE
The next one.
