Privacy notice vs privacy policy: what does your SME need?

The names are often used interchangeably. The important distinction is who the document is for and what it helps them do. A public notice explains your handling of personal information. An internal policy tells your team how to manage it.

Start with the reader

Someone sharing their information needs to understand what will happen to it. A staff member needs to know what action to take. Combining these two needs into one long document can make both harder to find.

Public privacy notice

Write for customers, applicants, website visitors or another clearly identified group. Explain the relevant data, purposes, sources, disclosures, choices and contact route in language that audience can understand.

Internal privacy policy

Write for the people operating the business. Identify responsibilities, approved handling practices, access controls and routes for raising requests or incidents. Link to detailed procedures where necessary.

Why a website template may not fit your business

A template cannot tell you where your data goes. Before drafting, list the forms, inboxes, messaging tools, cloud systems and suppliers involved. Check whether the business collects information directly or receives it from someone else. Then compare the proposed wording with those actual processes.

Use specific descriptions

“We use information to provide services” may be too broad to help a reader. Describe the relevant activity, such as responding to an enquiry, arranging a delivery or considering an application. Do not claim safeguards or certifications that you have not established.

A fictional recruitment example

Imagine a small recruitment firm receiving CVs by email and sending shortlists to clients. Its candidate notice would explain this collection and sharing, the relevant choices and how candidates can contact the business. Its internal policy would allocate responsibility for access and handling. A separate procedure would tell staff how to review old CVs or route a correction request. This is an invented illustration, not a client engagement.

Check Malaysian notice requirements

Malaysia’s Personal Data Protection Department provides guidance on the Notice and Choice Principle, including providing notices in Bahasa Malaysia and English. The required details should be checked against the applicable law and the processing involved. A website notice does not automatically cover employee records, recruitment or every customer interaction.

Keep the documents connected to operations

Give each document an owner and a review date. Review it when collection forms, purposes, suppliers, services or operating markets change. Test whether a staff member can find the relevant procedure and whether the public contact route reaches someone who can respond. Publishing a notice alone does not implement a privacy framework.

Official reference: Malaysia privacy-notice guidance (PDF)

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