Your UK company will likely need a privacy policy if it collects or processes personal data, meaning any information relating to an identified or identifiable individual.
The UK's implementation of the General Data Protection Regulation (Regulation (EU) (2016/679) as the “UK GDPR”, imposes transparency obligations on companies and requires certain information to be provided to an individual both where personal data is collected directly from an individual (for example, when an individual uses your company’s website, when an individual applies for a job or in an employment context) and when personal data is collected indirectly from an individual (for example, if your company buys a data set from a data broker, which you intend to use for marketing purposes). The UK GDPR contains a prescriptive list of content requirements that should be included in a privacy policy and the Information Commissioner’s Office (the UK data protection regulator) maintains practical guidance that can be used by your company to comply with your transparency obligations under the UK GDPR.
As a privacy policy is a public facing document, the risks of receiving complaints from an individual or indeed questions from a regulator for non-compliance with the UK GDPR are higher, and therefore is it important for your company to ensure that: (1) it has the necessary privacy policies in place; and (2) the privacy polices contain the information required under the UK GDPR.
Learn More: UK Founder Series: Compliance Matters