CIPP/E Study Guide
Ch 8.1.6 - Manner & format

How information must be provided (manner and format)

Article 12 governs the manner: information must be concise, transparent, intelligible and easily accessible, using clear and plain language, and language for children must be easy for children to understand. It may be given in writing, by electronic means (e.g. a website), or orally on request. The WP29 stresses 'provide' means controllers must actively furnish or direct subjects to the information - they must not have to hunt for it among T&Cs. It is usually free of charge, though a reasonable fee may be charged where a request is manifestly unfounded or excessive. Standardised icons and visualisation are permitted.

  • Form: concise, transparent, intelligible, easily accessible, in clear and plain language; children's information especially easy to understand.
  • Means: in writing or by other means, including electronic means (e.g. a website) - especially where many parties and technical complexity (e.g. online advertising) make processing hard to follow.
  • Orally: allowed on request; for Article 13/14 information the WP29 says identity need not first be proven by other means.
  • Cost: usually free of charge; a reasonable fee (administrative cost) may be charged only where a request is manifestly unfounded or excessive.
  • 'Provide' is key: controllers must actively furnish or direct subjects to the information - not bury it among terms and conditions.
  • Format aids: visualisation and standardised icons permitted; where presented electronically, icons must be machine readable
Don't make them hunt

The word provide in Articles 13/14 means the controller must take active steps - either furnish the data subject with the information or direct them to it - without the subject having to search for it amongst other content like terms and conditions.

Key terms - quick answers

What is “Clear and plain language”?
Article 12 standard requiring information be easy to understand for its audience, avoiding jargon; children's information must be especially simple.
What is “Standardised icons”?
Machine-readable visual symbols the GDPR permits to give an easily visible, understandable overview of processing; the Commission may adopt delegated acts on them.