The processing policy is the operator's mandatory public document: who the operator is, what data is collected and why, who receives it (including counters and widgets), retention and deletion, the subject's rights. It lives on its own page reachable from every page, and is linked at every data-collection form. Absence or unavailability is an offence under Art. 13.11(3).
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The most common hole: the policy covers forms but is silent about analytics, pixels and chats — precisely the parties receiving data from the first second.
A dedicated page (usually /privacy or /policy), a footer link on every page, plus the mandatory link at every form next to the consent element. The document opens without registration and stays current: a new counter or CRM is a reason to bump the version.
The scanner verifies the policy's presence, the link's reachability, and the point-of-collection link at every form — across several pages at once. On RU sites the policy often lives inside the consent document; the scanner recognises that variant too.
Regulators fine sites for processing personal data without consent — and a site starts processing earlier than it seems: analytics, pixels and widgets write cookies the moment the page loads. The scanner shows the auditor's view: what leaves for third parties before consent, whether the banner works, and whether forms collect data correctly.
Three sessions per page: no action, banner accepted, banner rejected.
Service catalogue: who receives visitor data and in which country.
The policy link and consent element are checked next to the form, not in the footer.
Report with an HMAC integrity stamp — hand it to your lawyer or contractor.
preparing for an audit
technical facts for an opinion
client site handover
consent regression monitoring
Scheduled re-checks with an alert when pre-consent trackers appear on your site.
Sign up freeAs a skeleton — yes, but the data list, purposes and third parties are unique per site. A template with someone else's purposes is worse than nothing: it asserts a falsehood.
Different ones: the policy describes how the operator handles data; the consent is the subject's expression of will. In practice they are often published side by side.
On every change to the data, purposes or third parties: a new chat widget or counter already qualifies.
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