Consider a freelancer like a web developer, or a consultant, or a lawyer, etc. Their jobs involve, one way or another, handling some personal data: contents of databases, authentication data, private information of any kind, etc. Therefore, I believe such professionals always need to have a privacy policy written somewhere and comply with the GDPR. But do they also need to show it to their clients, and have their clients sign it? I guess not, unless consent is required. However I'm not completely sure.

So what I'm asking basically is, if a professional or a worker in general handles personal data reasonably in the "expected" way (that is, they won't sell it, don't use it for marketing purposes, etc.), is such professional required to show the privacy policy to the clients, even if the clients don't ask for it? If consent is not required, then there's no need to sign or accept anything, so I would expect this privacy policy to just be an "informative" document, rather than something required by law. In any case a signature would not be required I guess.

In a similar situation on the web, a website would have a link to the privacy policy somewhere in the footer (not very noticeable), and no banners, no notices, or checkboxes of any kind. I'm basically looking for the equivalent "in real life".

  • 2
    This might be down to the way things are implemented in national law, but when I (in Germany) go to the doctor, the vet, or basically use any service that requires me to provide personal data I have to sign a document that explains how, and by whom. my data will be used.
    – user9838
    Commented Nov 20, 2020 at 19:11
  • @EikePierstorff, right, I guess health data is "sensitive data" though, so it might depend on what kind of personal information is involved.
    – reed
    Commented Nov 20, 2020 at 19:14

1 Answer 1


The freelancer is a data processor under GDPR

Data processors have similar but different obligations under GDPR as data controllers. Having a privacy policy is the least of them.

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