Just-in-time privacy notices

Online users like you and me constantly interact with platforms and services, often sharing personal data with them. Organisations usually present traditional privacy notices (often lengthy and complex) during the initial registration or at the data collection point. However, users frequently overlook these notices or misunderstand them. This has led to the emergence of just-in-time privacy notices, a more effective approach to informing users about data practices precisely when needed.

This post is intended for privacy officers, compliance managers, app developers, UX/UI designers, and business leaders responsible for data protection and user privacy within their organisations. It’s also valuable for legal professionals and consultants who advise on privacy and data protection laws.

Readers will understand just-in-time privacy notices, including a definition, benefits, and best practices for implementation. You’ll also learn how these notices can enhance user transparency and trust, ensure regulatory compliance, and reduce privacy fatigue.

What are just-in-time privacy notices?

Just-in-time privacy notices are brief, context-specific notifications informing users about data collection, use, and sharing practices when they engage in an activity that triggers these practices.

Unlike traditional privacy policies, these notices are concise and relevant to the user’s immediate action. The outcome? Increased likelihood that users will understand and consent to the data practices.

Examples and use cases

Mobile applications

• Location access: When a user opens a map application and requests directions, a just-in-time notice can appear, explaining that the app will access their location data to provide accurate navigation.
• Camera and microphone access: For social media or communication apps, a notice can appear when the user tries to upload a photo or start a voice call, informing them that the app will need access to their camera or microphone.

E-commerce websites

• Payment information: During the checkout process, a just-in-time notice can inform users about how the platform will process, store and protect their payment information.
• Personalisation: If the website uses cookies to personalise the shopping experience, a notice can appear when the user first visits the site or adds items to their cart, explaining how the platform will use their browsing data.

Smart devices

• Voice assistants: When a user activates a voice assistant for the first time, a just-in-time notice can inform them about how their voice commands are recorded, processed, and potentially shared with third parties for improving the service.
• Smart home devices: For devices like smart thermostats or security cameras, notices can appear when the user sets them up, explaining how the collected data will be used to optimise performance or ensure security.

Social media platforms

• Data sharing: When a user connects their social media account to a third-party service, a just-in-time notice can explain what data will be shared and how it will be used by the third-party service.
• Privacy settings: When users change their privacy settings, a notice can provide immediate feedback on what these changes mean for their data visibility and sharing.

Benefits of just-in-time privacy notices

1. Enhanced user understanding and control: By providing information at the moment it is most relevant, users are more likely to comprehend and retain the details about data practices.
2. Increased transparency and trust: These notices help build trust between users and service providers by demonstrating a commitment to transparency and user-centric data practices.
3. Regulatory compliance: Just-in-time notices can help organisations comply with privacy regulations, such as the GDPR and CCPA, which emphasise the importance of informed consent and transparent data practices.
4. Reduction in privacy fatigue: Traditional privacy policies can be overwhelming, leading to privacy fatigue where users ignore important information. Just-in-time notices mitigate this by delivering information in manageable, context-specific chunks.

Best practices for implementing just-in-time privacy notices

Relevance and timing

Ensure that the notice is directly related to the user’s current action and appears at the appropriate time.

Clarity and conciseness

Use simple language and keep the notice brief to ensure it is easily understood by users.

Actionable information

Provide users with options to manage their data preferences, such as opting in or out of data collection or adjusting privacy settings.

Consistency

Maintain a consistent approach to privacy notices across all user interactions to avoid confusion and build a cohesive user experience.

How ITLawCo can help

Implementing just-in-time privacy notices requires a deep understanding of both legal and technical aspects of data protection. ITLawCo offers comprehensive services to assist organisations in developing and deploying these notices effectively:

1. Legal compliance and policy development: Our team of experts will ensure your just-in-time privacy notices comply with relevant regulations, such as the GDPR and CCPA. We help draft clear and concise notices tailored to your specific needs and user interactions.
2. User experience design: We collaborate with your design and development teams to integrate privacy notices seamlessly into your platform, ensuring they are user-friendly and non-intrusive.
3. Training and awareness: ITLawCo provides training sessions for your staff to understand the importance of just-in-time privacy notices and how to implement them effectively.
4. Ongoing support and monitoring: We offer ongoing support to ensure your privacy notices remain up-to-date with changing regulations and evolving best practices. Our team can also monitor user feedback and make necessary adjustments to improve the effectiveness of your notices.

Contact us today.