GDPR A14-01: Privacy Notice Requirements for Indirect Data Collection
When you collect personal data about individuals without their direct involvement, GDPR Article 14 requires you to provide specific privacy information within one month. This control ensures data subjects understand how their data is being used, even when you didn't collect it from them directly.
What this means
GDPR A14-01 mandates that organizations provide data subjects with a comprehensive privacy notice when personal data is obtained from sources other than the individual themselves. This notice must be delivered within a reasonable timeframe—maximum one month from data receipt—and include details about your organization, the purposes of processing, legal basis, recipient information, and data subject rights. The requirement applies across all indirect collection scenarios, from third-party data purchases to employee referrals or public records.
How to comply
- 1.Identify all sources where you collect personal data indirectly (third parties, public records, brokers, partners).
- 2.Create a standardized privacy notice template that covers all GDPR Article 14 mandatory information.
- 3.Document the collection date for each indirect data source to track your one-month deadline.
- 4.Deliver the privacy notice via appropriate channels (email, letter, or website access) within 30 days of obtaining the data.
- 5.Maintain records proving when notices were sent and to whom for audit purposes.
- 6.Review and update notices whenever your processing purposes or legal basis changes.
- 7.Establish escalation procedures for cases where contact information is unavailable or outdated.
Evidence auditors look for
- Privacy notice templates specifically labeled for indirect collection scenarios.
- Timestamped delivery logs showing notices sent within 30 days of data receipt.
- Data source registry documenting all third parties and indirect collection points.
- Email or postal records confirming notice delivery to data subjects.
- Version control documentation showing notice updates aligned with processing changes.
- Proof of inability to contact (bounced emails, returned mail) where deadline extensions apply.
- Internal process workflows defining responsibility for notice delivery by data source type.
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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