ITALY Trends and Developments Contributed by: Paolo Balboni, Luca Bolognini, Davide Baldini and Nicolò Maria Salvi, ICT Legal Consulting
Standardised Set of Icons Approved by the Garante for Clearer Privacy Notices Under Article 12 GDPR, the data controller is required to provide data subjects with the nec - essary information on the processing of their personal data “in a concise, transparent, intelli - gible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child”. In order to achieve this result, Article 12 further recom - mends that such information “may be provided in combination with standardised icons in order to give in an easily visible, intelligible and clearly legible manner, a meaningful overview of the intended processing. Where the icons are pre - sented electronically, they should be machine- readable”. Although not mandatory, the use of icons under the GDPR is therefore a good practice, which can help data controllers to achieve the high transparency requirements set by the GDPR, proactively demonstrating compliance in light of the principle of accountability. This is espe -
cially true in the case of complex data process - ing operations and/or where the information is specifically addressed to a child, as the use of standardised icons can help enhance the clarity and overall transparency of privacy notices. Against this background, in March 2021 the GPDP launched a contest titled “Easy privacy information via icons? Yes, you can!” aimed at stimulating the development of a standardised set of icons by software developers, tech profes - sionals, experts, lawyers, designers, university students, and anyone interested in the topic. On 15 December 2021, the Garante published on its website the three sets of icons deemed to be most effective, based on the following criteria: concept (which includes the aspects of effec - tiveness and conciseness); visual (graphics, readability, clarity); originality; and inclusiveness (gender equality, non-discrimination). The three winning projects are currently available on the GPDP’s website and can be freely used by any data controller who wishes to render its privacy notices more transparent.
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