learn-gdpr-with-phoebe / Practitioner session 3 of 8
Learn GDPR with Phoebe · Practitioner track · Session 3 of 8

Privacy notices and transparency

Transparency is the GDPR obligation people meet first, because it is the one visible on your website. Articles 13 and 14 spell out what you must tell people about what you do with their data, and when. A notice that lists cookies but hides the lawful basis, the retention period, or the right to complain is not compliant - just familiar. This session turns the requirement into a checklist and rebuilds Lumina's notice against it.

🟡 Practitioner track DPOs · marketers · ops No jargon Medium
0-3 · Welcome 3-18 · Concepts 18-40 · Build-along 40-45 · Q&A
Part 0

The obligation on your homepage

Everything else in the GDPR happens behind the scenes; transparency is the part the public sees. It is also the cheapest to get materially wrong, because most privacy notices were written to look like everyone else's rather than to satisfy Articles 13 and 14. The good news: the required content is a finite list. Once you have the checklist, auditing any notice - yours or a vendor's - takes minutes.

Read this first Educational, not legal advice. Verify against the Regulation text and get advice before publishing a notice.
Live - presented in session Self-study - full depth after class ★ Try it now Sources covered at the end
★ What you build today The Article 13/14 content checklist, the timing rules for direct vs indirect collection, the layered-notice pattern, and a rebuilt privacy notice for Lumina that would survive an audit.
Part 1 · covers Articles 13 & 14

What you must tell people 7 min live

Two articles, one checklist. Article 13 covers data you collect directly from the person; Article 14 covers data you get from somewhere else. The content overlaps heavily.

A compliant notice tells the person: Who you are + DPO Purposes + lawful basis Recipients Transfers + safeguards Retention period Their rights Withdraw consent Right to complain Most notices list purposes but omit the lawful basis, retention, and the right to complain. Those are required.
🔍 Click to zoom - the required contents of a privacy notice
LiveThe content checklist3 min▶

A compliant notice tells the person, in clear and plain language:

  • Who the controller is and how to contact them (and the DPO, if you have one).
  • The purposes and the lawful basis for each (and the legitimate interest, if you rely on it).
  • Who receives the data (recipients or categories of them).
  • Any international transfers and the safeguard used.
  • The retention period (or how it is decided).
  • Their rights (access, rectification, erasure, restriction, portability, object) and the right to withdraw consent.
  • The right to complain to a supervisory authority.
★ Try it now (any chat AI)Give me the GDPR Article 13 privacy-notice checklist - everything a notice must tell a person whose data we collect directly. Then review this notice text against the checklist and tell me what is missing: [paste a real privacy notice].
LiveDirect vs indirect, and timing3 min▶
  • Article 13 applies when you collect data from the person - the notice must be there at the time of collection (the signup form, the checkout).
  • Article 14 applies when you get data from somewhere else (a data provider, a partner) - you must inform the person within a reasonable period, at the latest one month, or at first contact.
  • Article 14 adds one item: you must tell the person the source of the data, since they did not give it to you directly.
The PDPA parallel The PDPA's Notification Obligation also requires stating your purposes on or before collection - so a good GDPR notice largely satisfies the PDPA too. The GDPR simply requires more items (lawful basis, retention, the fuller rights list, the complaint right).
Part 2 · transparency in practice

Make it readable 8 min live

A notice can contain everything required and still fail transparency if nobody can read it. Article 12 demands clear, plain language - which is why the layered notice exists.

Layer 1 · the short version who, why, your rights - in a few plain lines Layer 2 · the full notice every required item, for anyone who wants the detail A short summary that links to the full detail satisfies both "complete" and "clear".
🔍 Click to zoom - the layered notice
LiveClear language + the layered pattern3 min▶
  • Article 12: the information must be concise, transparent, intelligible, and in clear and plain language - especially for anything aimed at children.
  • The layered notice resolves the tension between "complete" and "readable": a short top layer (who, why, your rights, a link) over a full second layer with every required item.
  • Put it where the data is collected: a link at the signup form and checkout, not buried three clicks deep.
Real world

Lumina rewrites its notice. Lumina's old notice listed cookies and "we value your privacy" but never named a lawful basis, a retention period, or the right to complain. The rebuild added those, split into a short summary plus a full version, and put the link on the signup form. Same company, a notice that now matches Articles 13 and 12.

Self-studyThe notice as the front door to the rights2 min read▶

It is easy to treat the privacy notice as a legal formality, but it is really the front door to every right you learned in the leader track. The notice is where a person first learns they can ask for access, erasure, or portability, and where they find the channel to do it and the authority to complain to. A notice that omits the rights (or hides the contact) does not just breach Article 13 - it suppresses the rights downstream, because people cannot exercise what they do not know they have. So when you audit a notice, do not only check that the items are present; check that a real person could read it and know, concretely, what they can ask for and how. That readability test is the difference between a compliant document and an honest one.

Build-along · take it further

Audit a real notice ★ 10 min · pen and paper

Run the checklist against a notice you actually use.

Open your own (or your company's) privacy notice. Tick each checklist item present: controller + contact, purposes, lawful basis, recipients, transfers, retention, rights, withdraw consent, right to complain.

Circle the missing ones. The three most commonly absent: lawful basis, retention period, and the right to complain to an authority.

Check readability: could a non-lawyer skim the top and know who has their data, why, and what they can ask for?

Check timing: is the notice actually shown at collection (the form, the checkout), or hidden in a footer?

★ Lumina after b3 Lumina's notice now names every required item, reads in plain language, and appears at the point of collection. The rights it lists are real - which sets up b4, where an EU user actually exercises one and Lumina has to deliver within a month.
Homework

Before session b4 ◐ 40 min total

Source material

Official sources covered

Taught from the GDPR text. This page covers ~80% of the working content on transparency.

✓GDPR Articles 13 & 14 (information to provide)Part 1 · the content checklist + direct vs indirect + timing
✓GDPR Article 12 (clear and plain language)Part 2 · readability + the layered notice
◐PDPA Notification Obligation (s.20) contrastPart 1 · state purposes on/before collection
Check yourself

Three questions before you go 🎯 ◐ 90 seconds

1 · Which is commonly MISSING from a non-compliant privacy notice but REQUIRED by Article 13?

Most notices list purposes but omit the lawful basis, the retention period, and the right to lodge a complaint - all required by Article 13.

2 · When you obtain personal data from a third party (not the person), Article 14 adds the duty to tell them...

Article 14 (indirect collection) mirrors Article 13 but adds the source of the data, since the person did not provide it to you directly.

3 · The "layered notice" pattern exists to...

Article 12 demands clear, plain language while Article 13 demands completeness. A short readable top layer over a full second layer satisfies both.

Practitioner session 3 cheat sheet · pin this

The checklistWho you are + DPO, purposes + lawful basis, recipients, transfers, retention, rights, withdraw consent, right to complain.
Most-missed itemsLawful basis, retention period, right to complain to an authority.
Art 13 vs 1413 = collected from the person (notice at collection). 14 = from elsewhere (+ tell them the source).
TimingArt 13 at collection; Art 14 within a reasonable period (at most a month) or first contact.
Clear + plain (Art 12)Concise, intelligible language. Completeness alone is not transparency.
Layered noticeShort summary up top, full detail beneath - complete AND readable.
Put it at collectionLink on the form and checkout, not buried in a footer.
PDPA parallelPDPA Notification also wants purposes stated at collection - a good GDPR notice covers it.