Compliance Toolkit/Master Privacy Policy Template
MPA-DP-001 Standalone Template Privacy Notices & Policies
Compliance Toolkit · Standalone Template

Master Privacy Policy Template

A comprehensive, adaptable privacy policy aligned to the Data Protection Act, 2019

Template No.
MPA-DP-001
Published
July 2026
Format
23 sections · Fillable PDF
Version
1.0
Classification
Public
Language
English
Abstract

A 23-section master privacy policy organisations can adapt to publish a compliant, transparent notice covering data collection, lawful bases, AI-assisted processing, cross-border transfers, data subject rights and complaints handling.

Editable Template

Bracketed placeholders such as [Organisation Name] and [Insert Effective Date] mark the fields to complete. Download the fillable PDF (or request the source Word file) to adapt this template to your organisation before publication.

About This Template

This Master Privacy Policy template gives an organisation a complete, publication-ready structure for the notice it owes data subjects under Article 31 of the Constitution and the Data Protection Act, 2019. It runs from foundational definitions and the categories of personal data collected through to lawful bases, cookies, AI-assisted processing and automated decision-making, data sharing, cross-border transfers, security, retention, data subject rights, children's data, marketing, and the complaints pathway to the ODPC. Each clause is drafted to be adopted as-is or adapted to the organisation's actual processing activities, with bracketed placeholders marking the fields that need organisation-specific detail.

Document Control

Template NumberMPA-DP-001
Document TypePrivacy Policy
Version1.0
Approved By[Board / Management]
Effective Date[Insert Effective Date]
Next Review Date[Insert Review Date]
Policy OwnerData Protection Officer
Document ClassificationPublic

Contents

  1. Introduction
  2. Scope
  3. Definitions
  4. Who We Are
  5. Information We Collect
  6. Sources of Personal Data
  7. Purposes of Processing
  8. Lawful Bases for Processing
  9. Cookies and Similar Technologies
  10. AI-Assisted Processing
  11. Automated Decision-Making
  12. Data Sharing
  13. International Transfers
  14. Data Security
  15. Data Retention
  16. Your Rights
  17. Exercising Your Rights
  18. Children's Data
  19. Marketing Communications
  20. Third-Party Websites
  21. Changes to this Policy
  22. Contact Information
  23. Complaints

How to Use This Template

Replace every bracketed placeholder with organisation-specific detail, delete any clause that does not apply to your processing activities, and route the completed document to your Data Protection Officer or legal counsel for sign-off before it is published or put into effect. Review on a fixed cycle (at least annually, or on any material change to processing activities) and keep a version history in the Document Control table.

Disclaimer: This template is provided for general informational purposes and does not constitute legal advice. Using this template does not create an advocate-client relationship with Muchangi Patrick & Associates Advocates. For organisation-specific drafting or review, please book a consultation.
PM

Patrick Muchangi

Advocate of the High Court of Kenya · Founder, Muchangi Patrick & Associates Advocates

Patrick Muchangi is an Advocate of the High Court of Kenya and founder of Muchangi Patrick & Associates Advocates, a Nairobi practice specialising in data protection, privacy, AI governance and technology law, and editor of the Kenya Privacy Law Review.