Legal Risks in General Board of Global Ministries' Privacy Policy: Critical Gaps & Compliance Solutions | Erayaha

## When Privacy Promises Fall Short: A Case Study on General Board of Global Ministries' Policy Risks

Imagine facing a €20 million GDPR fine or a class action lawsuit over unclear data sharing practices—this is the real risk uncovered in our review of General Board of Global Ministries' privacy policy. Our analysis reveals four critical legal and logical issues that could expose the organization to significant regulatory penalties and reputational damage.

1. Ambiguity in Data Sharing with Third Parties The policy states that personal information may be shared with third parties for targeted advertising and other purposes, but lacks explicit user consent mechanisms and clear opt-out instructions. This ambiguity creates a high risk of non-compliance with GDPR (Art. 7, 21) and CCPA/CPRA, where fines can reach up to €20 million or 4% of annual global turnover.

Legal Analysis

high Risk

Removed

Added

We may alsowill only share each of these categories of personal information for targeted advertising purposes with third parties thatafter obtaining explicit, informed consent from the data subject, and will provide usa clear and accessible mechanism for users to opt out at any time, in accordance with advertising servicesGDPR Article 7 and CCPA/CPRA requirements.

Legal Explanation

The original clause lacks clear consent and opt-out provisions, violating GDPR and CCPA/CPRA requirements for lawful data sharing. The revision ensures explicit user consent and opt-out rights, reducing regulatory risk.

2. Inconsistent Data Retention and Deletion Standards While the policy mentions retention "as long as necessary," it does not specify maximum retention periods or deletion protocols. This vagueness can lead to violations of GDPR Art. 5(1)(e) and CCPA Sec. 1798.105, risking regulatory scrutiny and costly remediation.

Legal Analysis

medium Risk

Removed

Added

We will retain your personal information only as long asfor no longer than is necessary to provide our Programs and Services to youfor the purposes stated in this policy, enhance your user experience, and otherwise as necessarywill specify maximum retention periods for our operationseach category of data. Upon expiration of these periods or as permittedupon user request, data will be securely deleted or required by applicable lawsanonymized in accordance with GDPR Article 5(1)(e) and CCPA Section 1798.105.

Legal Explanation

The original clause is vague and does not specify retention periods or deletion protocols, creating compliance gaps. The revision provides clear retention limits and deletion procedures, supporting regulatory compliance.

3. Unclear Legal Basis for Processing Sensitive Data The policy references processing sensitive information (e.g., health, ethnicity, SSN) but does not detail the specific legal basis or additional safeguards required under GDPR Art. 9 and CCPA/CPRA. This omission could result in unauthorized processing and severe penalties.

Legal Analysis

critical Risk

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Added

Sensitive Information, such as Social Security number, ethnicity, nationality, and health conditions, will only be processed where strictly necessary and with explicit consent or another lawful basis as required by GDPR Article 9 and CCPA/CPRA, and subject to additional safeguards such as encryption and access controls.

Legal Explanation

The original clause fails to specify the lawful basis and safeguards for processing sensitive data, risking unauthorized processing. The revision aligns with GDPR/CCPA requirements for sensitive data handling.

4. Insufficient Clarity on International Data Transfers The policy states an "endeavor to maintain an adequate level of protection" for cross-border transfers but lacks details on mechanisms (e.g., Standard Contractual Clauses, adequacy decisions) required by GDPR Art. 44-49. This exposes the organization to enforcement actions and potential data transfer bans.

Legal Analysis

high Risk

Removed

Added

In cases where such a cross-border transfer occurs, we endeavor to maintain an adequate levelFor all international transfers of protection in accordance withpersonal information outside the EEA, we will implement appropriate safeguards as required by GDPR Articles 44-49, includingsuch as Standard Contractual Clauses, where appropriateadequacy decisions, requiring contractual safeguards between entities transferring personal information and/or obtaining your expressexplicit consent to the transfer, and will provide users with clear notice of your personal informationthese mechanisms.

Legal Explanation

The original clause is non-committal and lacks detail on required safeguards for international transfers. The revision specifies compliance mechanisms, reducing risk of enforcement actions and data transfer bans.

Conclusion: Proactive Legal Protection is Essential Our examination shows that even well-intentioned privacy policies can harbor costly ambiguities and compliance gaps. Addressing these issues proactively can prevent regulatory fines, litigation, and reputational harm. Is your organization confident in its data sharing and retention practices? Are your cross-border data transfers fully documented and compliant? How would your privacy framework stand up to a regulatory audit?

This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai's terms of service for liability limitations.