Michael Ogbu

Introduction
In a digital world driven by data, privacy policies have outgrown their reputation as legal fine print. They have become frontline declarations of trust, transparency, and corporate integrity. In my last article, I discussed why privacy policies are essential not just for compliance, but for building credibility with clients and regulators alike.

Today, I’m taking it one step further. I’ve prepared a sample privacy policy designed specifically for Canadian B2B service providers – grounded in PIPEDA requirements – along with a practical checklist. This is your guide not just to write a privacy policy, but to build one that communicates values, meets expectations, and withstands scrutiny.

Sample Privacy Policy: Anatomy of Transparency and Trust
The sample privacy policy linked below is structured around core privacy principles that Canadian organizations are expected to uphold:

Purpose and Scope: Clearly defines what types of personal information are collected and why.
Consent: Reflects PIPEDA’s emphasis on meaningful consent – ensuring individuals understand how their data is being used.
Use and Disclosure: Outlines permissible uses of information and when it may be shared with third parties.
Safeguards: Describes security controls and risk mitigation strategies.
Access and Correction: Explains how individuals can request access to, or correction of, their personal data.
Retention and Disposal: Details how long data is kept and how it is securely destroyed.
Contact Information: Lists the privacy officer’s contact for questions, concerns, or complaints.

This policy is not meant to be copied wholesale; it’s a starting point. Each organization should tailor its content to reflect its unique operations, data flows, and stakeholder relationships.

Privacy Policy Checklist: What You Shouldn’t Miss
To accompany the sample policy, I’ve included a downloadable checklist to help privacy teams, managers, and business owners:

• Confirm they’ve addressed all core PIPEDA principles
• Ensure clarity in data use, storage, and sharing practices
• Include proper contact and access request procedures
• Regularly review and update their privacy policy
• Reflect new risks like AI usage or cross-border data transfers

One of the most common missteps is forgetting to update the policy when new digital tools or vendors are added. Privacy policies are not “set it and forget it” documents. They are living commitments that must evolve.

Compliance Is the Floor – Trust Is the Ceiling
Privacy compliance is the bare minimum. The real goal is to build and maintain trust. Especially in B2B relationships, clients increasingly expect transparency about how their data, or their customers’ data, is being handled.

A thoughtful, up-to-date privacy policy signals that your organization values more than just box-ticking. It demonstrates a proactive commitment to protecting information and a clear understanding of your legal obligations. It can also support smoother audits, vendor onboarding, and public-facing accountability.

Call to Action
Use the sample privacy policy and checklist to audit your current documentation or build a new one from the ground up. Reflect on whether your existing policy truly communicates your data values – and whether your team knows how to uphold them.

If you found this useful, share it with your peers in legal, marketing, or operations. Privacy is a shared responsibility – and the first step is writing it down.