GDPR

Fabio, let me offer you a different answer.

Not a template — but a perspective.

The most common GDPR mistake is thinking it’s about documents.

It’s not. It’s about systems.

You can take the most elegant privacy policy, copy it, tweak a few words, and still face enforcement… because your real data practices don’t match what the text says.

And that — under GDPR — is a violation in itself.

Now, yes: after six years, reforms that may help are coming.

The European Commission and EDPB are working on guidance — even simplified model texts for small businesses.

But again, here’s the catch:

Those texts will help only if your actual data flows, legal bases, and processor contracts are aligned.

Otherwise, they become liabilities disguised as help.

It’s something very common to get fined because of mentioning non applicable or non updated laws, or because of affirming to be complying with something that it’s not effectively implemented (eg.: data security measures and policies).

I’ve reviewed too many cases where businesses got fined not for bad intentions — but for good intentions poorly executed, using “ready-to-use templates” or AI-generated policies that looked fine… and failed under scrutiny.

Or simply by copying someone’s text.

I have also seen cases of DMCA notices about people copying others terms, and us, the lawyers, initiating lawsuits for IP infringement. Because, yes, templates and drafts are subject to IP of the law firms or lawyers who drafted them. And they are usually registered.

So my suggestion is:

Don’t ask for a template.

Ask: what do we really do with our users’ data, and why?

Start there. And build from there.

That’s how compliance — and trust — are built.

And that may also help you discover which systems are applicable to you. And which documentation you may need to prove the implemented systems.

Working the other side… it’s not a good idea in my experience.

Hope it helps!