id: "PT-05(01)" title: "Just-in-time Notice" family: "PT" family_name: "PII Processing and Transparency" sort_id: "pt-05.01" priority: "P2" implementation_level: "organization" parent: "PT-05" enhancement: True


Statement

Present notice of personally identifiable information processing to individuals at a time and location where the individual provides personally identifiable information or in conjunction with a data action, or {{ insert: param, pt-05.01_odp }}.

Guidance

Just-in-time notices inform individuals of how organizations process their personally identifiable information at a time when such notices may be most useful to the individuals. Individual assumptions about how personally identifiable information will be processed might not be accurate or reliable if time has passed since the organization last presented notice or the circumstances under which the individual was last provided notice have changed. A just-in-time notice can explain data actions that organizations have identified as potentially giving rise to greater privacy risk for individuals. Organizations can use a just-in-time notice to update or remind individuals about specific data actions as they occur or highlight specific changes that occurred since last presenting notice. A just-in-time notice can be used in conjunction with just-in-time consent to explain what will occur if consent is declined. Organizations use discretion to determine when to use a just-in-time notice and may use supporting information on user demographics, focus groups, or surveys to learn about users’ privacy interests and concerns.

Assessment Objective

a notice of personally identifiable information processing is presented to individuals at a time and location where the individual provides personally identifiable information, in conjunction with a data action, or {{ insert: param, pt-05.01_odp }}.

Personally identifiable information processing and transparency policy and procedures

privacy notice

privacy plan

other relevant documents or records

Organizational personnel with personally identifiable information processing and transparency responsibilities

organizational personnel with user interface or user experience responsibilities

organizational personnel with information security and privacy responsibilities

Organizational processes and implementation support or mechanisms for providing notice to individuals regarding the processing of their personally identifiable information