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Creating a privacy policy for your business can seem daunting, especially if you are unsure about what you need to cover. The Privacy Commission provides guidance for privacy statements on their website, but this likely would not be enough for your privacy policy. A quick Google search will yield several options for template privacy policies online, but you must exercise caution with these. The best privacy policy is one that is tailored to your business and can meet your unique needs. This article will provide some guidance on: 

  • when you would need a privacy policy; and 
  • why you should avoid using a template privacy policy for your business.

When Do I Need a Privacy Policy?

If your business collects personal information, then you classify as an ‘agency’ under privacy law in New Zealand. Therefore, you must uphold your obligation to protect the privacy of your customers and be transparent about what personal data you collect. Personal information is data that you can use to identify an individual, such as:

  • full names;
  • physical addresses;
  • IP addresses;
  • photos; and
  • payment details.

A good way to meet your disclosure obligations is to have an easily accessible privacy policy on your website. That way, customers know that you are collecting their personal data and why. Make sure that customers can easily find your privacy policy without having to browse extensively for it.

For example, you may have your privacy policy on a sign by the till of your store. Alternatively, you could put a link to your privacy policy page with other administrative links at the bottom of your webpages.

What Goes Into a Privacy Policy?

An acceptable privacy policy should be:

  • transparent;
  • easily understandable; and
  • comprehensive.

You want to make sure it covers all aspects of how your business handles privacy matters. You need to outline how you collect, store, and use your customers’ personal data. So, make sure your privacy policy has clauses that cover:

  • what information you collect;
  • how you collect information;
  • why you collect information;
  • your storage and security measures;
  • what you use personal information for;
  • when you share information with third parties;
  • when customers can access their information
  • any legal disclaimers; and
  • how your customers can contact you.

For example, if you collect website visitors’ personal information through cookies for web analytics purposes, you would need to outline this in your privacy policy. You may also need a cookie consent pop-up notice.

Template vs Tailored Privacy Policy

Using a template privacy policy can be convenient and easy for your business. However, you are likely to run into several problems if you use a vanilla privacy policy template from the internet. 

Relevance for Your Business

For one thing, a template privacy policy is not written for the unique circumstances of your business. No two businesses are alike, so they should not have identical privacy policies. The personal information that your business collects will likely differ from what another collects.

For example, your business’ app will likely gather very different personal information than what a cafe’s delivery service will collect.

You need to craft your privacy policy to protect all aspects of your business and limit your own liability regarding your privacy obligations. A template policy may not cover all of these legal disclaimers.

For example, you need to provide a detailed list of all of the personal information that your business collects in your privacy policy, such as customers’ contact details. A template privacy policy will not provide this specificity.

Specialist Areas

Your privacy policy will change depending on your business’ nature and the industry you trade in. Therefore, you may need more specific clauses applying to the specialist areas of your business. 

For example, if your business solely operates online, then it may be a good idea to include a cybersecurity policy and a cookies policy in your privacy policy. A template may not provide these.

Application in NZ

If you find a template privacy policy generator online, it may tailor to a different country’s laws. Your privacy policy needs to cover your New Zealand privacy law obligations, and you cannot be certain that a template will be adequate for NZ law.


A good privacy policy gets to the point and uses plain language so that customers understand how your business uses their information. If you draft your privacy policy yourself with the appropriate legal advice, then you can make sure that you get across your points in a way that customers understand. If you are using a template privacy policy that uses legal jargon that even you cannot read, then chances are your customers will not be able to either.

Key Takeaways

Using a template privacy policy that you find online can certainly be convenient and quick. However, you may find that you run into legal issues later on as you cannot be sure that a template policy adequately meets your legal obligations as an agency. Using a privacy policy that is tailormade for your business means that you can be more confident that you are meeting these obligations. If you would like more information or help with your business’s privacy policy, contact LegalVision’s New Zealand privacy lawyers on 0800 005 570 or fill out the form on this page.

Frequently Asked Questions

What is a privacy policy?

A privacy policy is a document that outlines what personal information you collect from your customers, how you do it, and why. This way, customers know how you are handling their personal data.

Do I need a privacy policy?

It is a good idea to have a privacy policy if you collect personal information from your customers. This is an easy way to let your customers know what information you collect from them and detail any other privacy issues.

Can I use a template privacy policy?

You can decide to use a template privacy policy. However, you may run into legal issues later on because it did not fully disclose to customers what personal data you collected or why. You cannot be sure that you are covering your full legal obligations with a template privacy policy.

What goes into a privacy policy?

Your privacy policy should detail how you handle your customers’ personal data and why. This includes detailing how you gather personal information, how you store and protect it, and how you use it.

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