Website documents and notification to Roskomnadzor
A website starts processing personal data with its first form and its first analytics counter, while the documents appear on it later and are most often copied from another website, written for other purposes of collection. We first work out what the website actually collects and prepare a set of documents for those purposes.
What is included
- A processing policy for the actual purposes of collection, confirmed by a review of the forms and counters
- Consents as separate documents: to processing, to mailings and to cookies
- Recommendations for remedying violations in the website’s interface and functionality
- A notification to Roskomnadzor, filed and accepted, with the entry in the register of operators
- Texts for forms, checkboxes and the cookie banner, with an indication of when each of them appears
Case study
Documents for an online learning platform before it opened to users
The request
The online learning platform Verbatica was preparing to launch. The website collected the data of pupils and parents from its very first forms, yet the platform had none of the documents that must be published by that moment.
What we did
We worked out which data the platform collects and through which forms, and prepared a set for the website: a personal data processing policy for the actual purposes, consents as separate documents and a user agreement. Separately we provided the wording for the forms and the order in which they appear on screen.
The result
The platform could be opened to users: from day one the data was collected on a lawful basis rather than formalised retroactively.
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