Privacy Notice Changes

West Virginia Executive Branch
Privacy Policy: Notice

Privacy Notice Changes

Question:

Do changes need to be made to the privacy notice when the use of the personal information (PI) collected changes?

Answer:

Privacy practices change over time. You may change the way you collect personal information (PI), the specific elements of PI that you collect, or the uses you make of PI. As these practices change, your privacy notices need to change too.

Here are some tips on when to revise your privacy notices:

• If you are updating forms used to collect PI, you should determine the data elements that are going to change. Do you now collect additional PI for authentication purposes, such as, an email address or cell phone number? The uses of these new data elements should be covered in a revised privacy notice.
• If you move to a new technology (such as from paper forms to online forms), you should also review the applicable privacy notice. For example, individuals may have been able to leave boxes blank on a paper form, but now be required to provide the information online. Similarly, the online form might collect new types of PI, such as session information. The privacy notice should reflect the changes.
• If you want to use PI for new purposes, you also need to update the privacy notice to reflect the new uses. Depending on the use, you may also need to include additional new information, such as information about choices.

It’s a good idea to review your privacy notices periodically even if you aren’t aware of any specific changes. You can ask those co-workers that use PI if their uses have changed. You can also update the privacy notices to clarify any points that trigger reader questions.

Note: Your agency/bureau/department/division may have specific requirements – always check your policies and procedures. If you have questions, contact your Privacy Officer.