Privacy Policy Template for Cloud Service Providers

A comprehensive privacy policy is essential for ISO 27018 compliance. This template provides a framework for cloud service providers to create transparent, compliant privacy documentation.

Privacy Policy Structure

Required Sections for ISO 27018 Compliance

Introduction and Scope
Information We Collect
How We Use Your Information
Data Sharing and Disclosure
Data Retention
Your Rights
Security Measures
International Transfers
Sub-processors
Updates and Contact Information

Complete Privacy Policy Template

1. INTRODUCTION AND SCOPE

Template:

Privacy Policy for [Company Name] Cloud Services

Effective Date: [Date]
Last Updated: [Date]

[Company Name] ("we," "us," or "our") is committed to protecting the privacy
and security of personally identifiable information (PII) processed through
our cloud services. This Privacy Policy describes our practices for collecting,
using, storing, and disclosing PII in accordance with ISO 27018 and applicable
privacy laws.

Scope:
This policy applies to:
- [Service Name] cloud platform
- All customer data processed through our services
- PII collected directly from service users

This policy does NOT apply to:
- Customer's use of data within our platform (covered by customer's own privacy policy)
- Third-party services linked from our platform
- Customer's internal data processing practices

Customization Notes:

Clearly define which services and data are covered
Distinguish between CSP's role and customer's role
Update dates with each policy revision

2. INFORMATION WE COLLECT

Template:

2. INFORMATION WE COLLECT

We collect information in three ways:

2.1 Information You Provide Directly
When you create an account or use our services, you provide:
- Account Information: Name, email address, company name
- Billing Information: Payment method (processed via [payment processor])
- Support Information: Information you provide when contacting support
- Optional Information: [List any optional profile fields]

2.2 Information We Collect Automatically
When you use our services, we automatically collect:
- Usage Data: Feature usage, click patterns, time spent (aggregated and anonymized)
- Technical Data: IP address, browser type, device type, operating system
- Log Data: Access logs, error logs, performance data

2.3 Information from Third Parties
We may receive information from:
- Authentication Providers: If you use SSO (e.g., Google, Microsoft)
- Sub-processors: Information necessary for service delivery
- Payment Processors: Transaction confirmation (no raw payment data stored)

2.4 Information We Do NOT Collect
We do not collect or process:
- Customer's end-user PII (we are a processor, not controller)
- Special category data (health, biometric, etc.) unless explicitly contracted
- Data from children under 16 without parental consent
- Marketing data without explicit consent

Customization Checklist:

List all PII fields actually collected
Specify which fields are required vs. optional
Name third-party services that provide data
Be explicit about what you DON'T collect

3. HOW WE USE YOUR INFORMATION

Template:

3. HOW WE USE YOUR INFORMATION

We use collected information only for documented, legitimate purposes:

3.1 Service Provision (Legal Basis: Contract Performance)
- Creating and managing your account
- Providing cloud service functionality
- Processing transactions and billing
- Delivering customer support

3.2 Service Operation (Legal Basis: Legitimate Interest)
- Maintaining service security and integrity
- Preventing fraud and abuse
- Troubleshooting technical issues
- Ensuring service availability and performance

3.3 Service Improvement (Legal Basis: Legitimate Interest)
- Analyzing aggregated usage patterns (anonymized)
- Identifying and fixing bugs
- Developing new features
- Conducting quality assurance

3.4 Legal Compliance (Legal Basis: Legal Obligation)
- Complying with applicable laws and regulations
- Responding to valid legal requests
- Enforcing our terms of service
- Protecting rights and safety

3.5 Marketing Communications (Legal Basis: Consent)
- Sending product updates and newsletters (opt-in only)
- Providing information about new features
- Sharing relevant content and resources
- You may withdraw consent at any time via [unsubscribe method]

3.6 Prohibited Uses
We will NEVER:
- Use customer PII for our own marketing without explicit consent
- Sell or rent customer data to third parties
- Use PII for purposes beyond those stated above
- Process customer data for purposes not instructed by customer

Implementation Notes:

Link each purpose to its legal basis
Be specific about what "legitimate interest" means
Emphasize prohibited uses (builds trust)
Explain how to withdraw consent

4. DATA SHARING AND DISCLOSURE

Template:

4. DATA SHARING AND DISCLOSURE

We limit data sharing to essential service providers and legal requirements:

4.1 Sub-processors
We engage the following sub-processors to help deliver our services:

| Sub-processor | Service | PII Access | Location | Certifications |
|---------------|---------|------------|----------|----------------|
| [Name] | Infrastructure hosting | Account data | [Country] | ISO 27001, SOC 2 |
| [Name] | Payment processing | Payment info | [Country] | PCI DSS |
| [Name] | Email delivery | Email addresses | [Country] | SOC 2 |

Current sub-processor list: [URL]
We will notify customers 30 days before engaging new sub-processors.

4.2 Business Partners
We do not share PII with business partners without your explicit consent.

4.3 Legal Requirements
We may disclose PII when required by law:
- Valid court orders or subpoenas
- Law enforcement requests (after legal review)
- National security requirements
- Protection of rights and safety

When legally permitted, we will:
- Notify you before disclosure
- Challenge overbroad requests
- Disclose minimum necessary information

4.4 Business Transfers
If we are acquired or merged, PII may transfer to the new entity, subject to:
- This privacy policy remains in effect
- You will be notified of any material changes
- You may delete your account before transfer completes

4.5 What We Do NOT Share
- We do not sell customer data
- We do not share PII for advertising purposes
- We do not disclose customer data to competitors

Customization Requirements:

Maintain current sub-processor list
Include link to always-updated registry
Specify notification procedures
Document government request handling

5. DATA RETENTION

Template:

5. DATA RETENTION

We retain PII only as long as necessary for documented purposes:

5.1 Retention Periods

| Data Type | Retention Period | Reason |
|-----------|-----------------|--------|
| Account information | Duration of account + 30 days | Service provision |
| Billing records | 7 years after transaction | Tax and legal requirements |
| Support tickets | 3 years after resolution | Quality assurance |
| Usage logs | 90 days | Security monitoring |
| Marketing consents | Until withdrawn | Ongoing consent |
| Backups | 90 days | Disaster recovery |

5.2 Automated Deletion
- We automatically delete PII when retention periods expire
- Deletion is permanent and cannot be reversed
- You will receive notification before account deletion (if contact info available)

5.3 Early Deletion
You may request early deletion of your data at any time by:
- Closing your account via [method]
- Contacting us at [email]
- Your data will be deleted within 30 days

5.4 Legal Holds
Retention may be extended if:
- Required by law or regulation
- Necessary for legal proceedings
- Subject to regulatory investigation
You will be notified if a legal hold affects your data.

Implementation Tips:

Align retention periods with actual technical implementation
Document legal justifications for each period
Ensure automated deletion actually works
Provide easy account closure

6. YOUR RIGHTS

Template:

6. YOUR RIGHTS

You have the following rights regarding your PII:

6.1 Right to Access
- Request a copy of all PII we hold about you
- Receive information about how your PII is processed
- Response time: Within 30 days
- Method: [Email privacy@company.com]

6.2 Right to Correction
- Request correction of inaccurate PII
- Update your profile information at any time
- Method: [Settings > Profile] or [contact us]

6.3 Right to Deletion ("Right to be Forgotten")
- Request deletion of your PII
- Account deletion available at [Settings > Delete Account]
- Deletion completed within 30 days

6.4 Right to Data Portability
- Receive your PII in structured, machine-readable format (JSON, CSV)
- Transfer your data to another service provider
- Method: [Settings > Export Data] or [contact us]

6.5 Right to Restrict Processing
- Request limitation of how we process your PII
- Pause processing while we verify accuracy or assess legal basis
- Method: [Email privacy@company.com]

6.6 Right to Object
- Object to processing based on legitimate interest
- Opt out of marketing communications at any time
- We will cease processing unless we have compelling legitimate grounds

6.7 Right to Withdraw Consent
- Withdraw consent for any consent-based processing
- Does not affect lawfulness of processing before withdrawal
- Method: [Unsubscribe link] or [Settings > Privacy]

6.8 Right to Lodge Complaint
- File complaint with your data protection authority
- [Country] users: [Relevant DPA contact information]
- EU users: Contact your local supervisory authority

6.9 Exercising Your Rights
To exercise any rights:
- Email: privacy@[company].com
- Subject line: "Privacy Rights Request"
- Include: Your name, account email, specific request
- We will respond within 30 days

Compliance Notes:

Implement all rights in service backend
Test request workflows regularly
Train support team on privacy requests
Document response procedures

7. SECURITY MEASURES

Template:

7. SECURITY MEASURES

We implement comprehensive security controls to protect PII:

7.1 Technical Safeguards
- Encryption: AES-256 encryption at rest, TLS 1.3 in transit
- Access Controls: Role-based access, multi-factor authentication
- Network Security: Firewalls, intrusion detection, DDoS protection
- Secure Deletion: Cryptographic erasure and overwriting

7.2 Organizational Safeguards
- Security Policies: Comprehensive information security management system
- Employee Training: Annual privacy and security training for all staff
- Background Checks: All employees handling PII undergo screening
- Access Limitation: Strict need-to-know access principles

7.3 Monitoring and Response
- 24/7 security monitoring
- Automated threat detection
- Incident response plan
- Regular security assessments

7.4 Certifications and Audits
- ISO 27001: Information Security Management
- ISO 27018: Cloud Privacy Protection
- SOC 2 Type II: Security, availability, confidentiality
- Annual third-party audits

7.5 Data Breach Notification
In the event of a security incident affecting PII:
- We will notify you within 24 hours of discovery
- Notification will include: nature of breach, affected data, remediation steps
- We will cooperate with your breach notification obligations
- We maintain cyber insurance coverage

7.6 Security Documentation
- Security whitepaper: [URL]
- Compliance documentation: Available upon request
- Penetration test summaries: Available to customers under NDA

Audit-Friendly Elements:

Specific encryption standards
Certifications with dates
Quantified response times
Reference to detailed documentation

8. INTERNATIONAL TRANSFERS

Template:

8. INTERNATIONAL TRANSFERS

8.1 Data Locations
Your PII may be processed in the following locations:
- Primary: [Country/Region]
- Backup: [Country/Region]
- Sub-processors: See Section 4.1 for locations

You can specify preferred data regions during account setup.

8.2 Transfer Mechanisms
When transferring PII outside your country, we use approved mechanisms:
- European Commission Standard Contractual Clauses (SCCs)
- UK International Data Transfer Agreement (IDTA)
- Adequacy decisions where applicable
- Explicit consent for specific transfers

8.3 EU-US Data Transfers
For transfers from EU/EEA to the United States:
- We implement Standard Contractual Clauses
- Additional safeguards: [encryption, access controls, etc.]
- Transfer Impact Assessment completed and available upon request

8.4 Your Control
- Specify data residency requirements in your contract
- Object to specific country transfers
- Request data location changes (subject to availability)

8.5 Data Sovereignty
- We comply with local data protection laws in all operating regions
- You retain all rights to your data regardless of processing location
- We provide data residency guarantees in writing upon request

Important:

Keep data location information current
Update based on actual infrastructure
Document all transfer mechanisms
Conduct Transfer Impact Assessments

9. SUB-PROCESSORS

Template:

9. SUB-PROCESSORS

9.1 Sub-processor Management
We carefully vet and monitor all sub-processors handling PII:

Selection Criteria:
- ISO 27001 or equivalent certification required
- Data Processing Agreement with equivalent protections
- Regular security audits
- Acceptable data locations

9.2 Current Sub-processors
Maintained at: [URL to always-current list]

We will notify you 30 days before:
- Engaging new sub-processors
- Changing sub-processor services
- Changing sub-processor data access

9.3 Your Rights Regarding Sub-processors
- Object to new sub-processors on reasonable grounds
- Request removal of specific sub-processors (we will evaluate feasibility)
- Audit sub-processor compliance (through us or third-party auditor)

9.4 Sub-processor Obligations
All sub-processors must:
- Process PII only as instructed
- Implement equivalent security measures
- Notify us of any security incidents
- Delete or return PII upon contract termination
- Submit to audits

Operational Requirements:

Maintain public sub-processor registry
Implement notification system
Document objection process
Track sub-processor certifications

10. UPDATES AND CONTACT

Template:

10. UPDATES AND CONTACT INFORMATION

10.1 Policy Updates
- We may update this Privacy Policy to reflect service changes or legal requirements
- Material changes will be notified 30 days in advance via:
  * Email to registered account address
  * In-service notification
  * Notice on our website
- Continued use after effective date constitutes acceptance
- Policy version history: [URL]

10.2 Contact Information

Data Controller:
[Company Legal Name]
[Address]
[Country]

Privacy Officer / Data Protection Officer:
Email: privacy@[company].com
Phone: [Phone number]
Mail: [Address]

For privacy-related inquiries:
- General questions: privacy@[company].com
- Security concerns: security@[company].com
- Data subject requests: requests@[company].com
- DPO (EU): dpo@[company].com

Response Time: Within 5 business days for inquiries, 30 days for formal requests

10.3 Supervisory Authority
If you are unsatisfied with our response, you may contact:
[Relevant data protection authority for your jurisdiction]
[Contact information]

10.4 Additional Resources
- Security documentation: [URL]
- Compliance certifications: [URL]
- Data Processing Agreement (DPA): [URL]
- Transparency reports: [URL]

Implementation Checklist

Before Publishing:

Replace all [placeholders] with actual information
Verify all URLs work
Confirm sub-processor list is current
Review with legal counsel
Ensure technical claims match actual implementation
Get approval from Data Protection Officer
Check compliance with local regulations (GDPR, CCPA, etc.)

After Publishing:

Display prominently on website
Make available during signup
Include in Data Processing Agreements
Train customer support on policy
Set calendar reminders for annual review
Monitor for legal/regulatory changes

Ongoing Maintenance:

Quarterly review of accuracy
Update when services change
Track policy version history
Notify customers of material changes
Maintain change log

Privacy Policy Best Practices

Writing Style:

Use plain language, avoid legal jargon
Short sentences and paragraphs
Active voice
Clear headings and organization
Examples where helpful

Transparency:

Be honest about data practices
Don't hide information in fine print
Explain "why" not just "what"
Highlight user rights prominently

Accessibility:

Mobile-friendly formatting
Available in multiple languages
PDF download option
Print-friendly version
Accessible to screen readers

Trust Building:

Emphasize what you DON'T do with data
Highlight security measures
Reference certifications
Provide contact information
Link to security documentation

Common Mistakes to Avoid

❌ Copy-pasting from another company - Must reflect YOUR practices ❌ Vague language - "We may share data with partners" (who? when?) ❌ Overpromising - Only commit to what you can technically deliver ❌ Ignoring updates - Outdated policies create compliance gaps ❌ Hidden in legal section - Make privacy information prominent ❌ No contact information - Must provide way to exercise rights ❌ Inconsistent with terms - Privacy policy must align with other legal docs

Regional Variations

Additional Requirements for:

European Union (GDPR):

Name and contact of Data Protection Officer
Legal basis for each processing purpose
Details on automated decision-making
Right to object to profiling
Right to lodge complaint with supervisory authority

United Kingdom (UK GDPR):

Similar to EU GDPR
Reference UK ICO as supervisory authority
UK-specific transfer mechanisms

California (CCPA/CPRA):

Categories of personal information collected
Categories of sources
Business purposes for collection
Categories of third parties with whom shared
Consumer rights (access, deletion, opt-out)
"Do Not Sell My Personal Information" link

Brazil (LGPD):

Purpose of processing
Retention period
Shared responsibility (if applicable)
International data transfers
Rights under LGPD

Next Steps

After completing your privacy policy:

Have legal counsel review
Conduct Privacy Impact Assessment
Implement technical controls to support policy
Train staff on policy provisions
Integrate into Data Processing Agreements
Set up monitoring for compliance
Schedule annual review

Next Lesson: Control assessment worksheet - Evaluate your PII control implementation.