Transparency Notices: More Information Does Not Always Mean More Transparency
- 2 days ago
- 4 min read
A transparency notice, often called a privacy notice, is there to explain, in clear and accessible terms, what an organisation does with personal information.
For our customers, this is an important part of UK GDPR compliance. Service users, staff and applicants should be able to understand what information is collected, why it is used, the lawful basis relied upon, who information may be shared with, how long it is kept and what rights they have.
But I have always thought that there is an important distinction between providing information and being transparent.
Why are transparency notices needed?
The UK GDPR requires organisations to process personal data fairly and transparently. Articles 13 and 14 set out the information that should be provided to individuals.
The aim is not just to publish a large amount of legal information. It is to help people understand, in a meaningful way, what is happening with their information.
That means transparency notices should be clear, concise, accessible and written in language people can actually understand.
Why don't myKafico notices list every sharing partner and every project?
It can be tempting to make a privacy notice "comprehensive" by listing every organisation a practice might share information with, every individual project it participates in and every system it uses.
The problem is that a notice can become so long and detailed that virtually nobody can understand it.
A 40-page privacy notice containing hundreds of organisations, suppliers, research initiatives and one-off projects may technically contain more information, but that does not necessarily make the processing more transparent.
Our approach is therefore to describe meaningful categories of recipients and processing activities, while drawing particular attention to uses of information that are unusual, significant or likely to matter to the person reading the notice.
For example, it may be much more useful to explain that information can be shared with other health and care organisations involved in your care than to present patients with an enormous list of individual NHS organisations which may change over time.
At the same time, not every new project needs another permanent section added to the main notice. Sometimes a temporary or specific notice is much clearer.
The detailed information about every system, supplier, contract, project and data flow should still exist behind the scenes in things such as the practice's Record of Processing Activities, DPIAs and information sharing documentation.
The privacy notice has a different job which is to
explain what matters to the individual in a way they can realistically understand.
How to use the myKafico transparency notices
Practices with access to myKafico platform will find a Transparency Notices page in the left-hand menu.
1. Configure your notices
The page contains links to your transparency notices and before publishing them, you can tailor the notices by confirming what your practice actually does – for example, whether you:
send text messages to patients;
operate CCTV;
use AI scribes; or
undertake other particular types of processing covered by the notice.
The notice will then reflect the way your practice operates.
2. Add the links to your website
Once you are happy with the notices, simply send the relevant link to your website provider and ask them to add it to your practice website.
Because the notice is hosted through myKafico, you do not need to keep uploading replacement documents every time something changes.
3. Use the right notice for the right audience
There are separate versions for:
Patients
Employees
Candidates and job applicants
This means people receive information that is relevant to their relationship with the practice, rather than having to work through one enormous notice covering everything.
4. Use a Temporary Notice when something changes
There is also a Temporary Notice function which is useful where you want to draw particular attention to something new, for example, if the practice is introducing CCTV, trialling a new technology or starting a particular project.
You can create the temporary information and set an end date. It will appear alongside the main transparency information for the period you choose and then automatically drop off. This allows practices to be particularly visible about changes without permanently making the main privacy notice longer and longer.
5. Don't forget accessibility
myKafico also includes an Easy Read transparency notice, providing a more accessible version of the information for people who may find a standard privacy notice difficult to understand.
6. AI information page
The myKafico AI page is designed to engage patients more actively, with videos, information and quizzes explaining how AI may be used within the practice.
The aim is to help patients understand what these technologies actually do, where humans remain involved and what the use of AI means for them. No action needed here - it will be visible via the links,
Transparency should be designed for the person reading it
Our starting point is that a transparency notice should help an ordinary person answer some straightforward questions:
What information do you have about me? Why are you using it? Who might receive it? Is anything unusual happening with it? What choices or rights do I have?
If those answers disappear amongst dozens of pages of exhaustive detail, the notice has arguably become less transparent rather than more.
That is why the Kafico approach is based on meaningful, layered and proportionate transparency rather then simply putting more words on a webpage.
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