Re section 5 of the privacy policy template, (International data transfers). I am setting up as a sole trader for tax and bookkeeping services in the UK and using this template for my website. I do not sell any products or services via my website and users cannot log in. They can submit personal details in respect of an enquiry. My website is hosted on UK based servers. The first two paragraphs do not appear to apply. Can I delete these or is there a purpose for which I am not aware?
Thanks
Fiona
Alasdair Taylor's Answer
These paragraphs, in the current version of the template, read as follows:
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy policy.
Information which you provide may be transferred to countries [(including [the United States], [Japan], [other countries])] which do not have data protection laws equivalent to those in force in the European Economic Area.
Assuming you do not transfer any personal information of users outside the EEA, then you can delete these paragraphs. As mentioned in the footnote to this section, if you do transfer the personal information of users outside the EEA, then the inclusion of these paragraphs in a privacy policy will not in itself render such transfers lawful.
