CIPP/E Study Guide
IAPP Training · Module 6 - BoK III.C

Module 6 · Transparency (Article 12)

Transparency (Article 12) requires controllers to communicate concisely, transparently, intelligibly and in clear and plain language (adapted for children), in writing or electronically, or orally on request. 'Easily accessible' means the information is apparent without the person having to seek it out, and notice/access must be free of charge unless requests are unfounded or excessive. The Irish DPC fined Meta €390 million for transparency failures.

Transparency (Article 12) requires controllers to communicate concisely, transparently, intelligibly and in clear and plain language, adapted for children; in writing or by electronic means, or orally if requested. Easily accessible means the information is apparent without the data subject having to seek it out. Notice and access are free of charge unless requests are unfounded or excessive.

  • WP29: transparency applies to (1) providing fair-processing information, (2) communications about rights, and (3) facilitating the exercise of rights.
  • It must be concise AND complete - conciseness does not excuse omitting required detail.
Example fine

The Irish DPC fined Meta €390 million (EDPB binding decisions) for transparency failures over the legal basis for personalised ads.

Key terms - quick answers

What is “Transparency”?
Article 12: the principle that information and communications to data subjects be concise, intelligible, easily accessible and in clear plain language.
What is “Easily accessible”?
Information that is apparent to the data subject without their having to seek it out.