St. Lawrence Catholic School: Legal Risks in Privacy Policy & How to Fix Them | Erayaha

## When Privacy Policies Fall Short: The Hidden Costs for St. Lawrence Catholic School

Imagine a scenario where a single ambiguous clause in a privacy policy leads to a GDPR fine of €20 million, or a CCPA class action costing hundreds of thousands in damages. Our analysis of St. Lawrence Catholic School’s privacy policy reveals several such risks—each with the potential to disrupt operations, damage reputation, and incur substantial financial penalties.

1. Ambiguous Data Usage and Legal Basis The policy states that personal information is collected and used for a variety of purposes, but fails to specify the legal basis for processing as required by GDPR and CCPA. This lack of clarity exposes the school to regulatory scrutiny and potential fines up to 4% of annual revenue under GDPR.

Legal Analysis

high Risk

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We collect and process personal information that you voluntarily provide to us when registeringsolely for an event, filling out a connect card, giving to the churchspecific purposes outlined in this policy, signing up forand only with a newsletter,valid legal basis such as consent or any time you enter information into our site. The personal information that we collect depends on the context of your interactions with uslegitimate interest, the choices you makein accordance with applicable privacy laws including GDPR and the features you useCCPA.

Legal Explanation

The original clause is ambiguous regarding the legal basis for data processing, which is a requirement under GDPR and CCPA. The revision clarifies lawful grounds, improving enforceability and compliance.

2. Incomplete Disclosure of Third-Party Data Sharing While the policy claims data is not shared or sold to third parties except as required by law, it also allows third-party services to track user information. This contradiction creates confusion and could be interpreted as a deceptive practice under consumer protection laws, risking FTC action or state-level penalties.

Legal Analysis

high Risk

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At no time is thisPersonal data will not be shared with (or sold to) third parties or other attendees of St. Lawrence Catholic School, except as required by law. ... Allow St. Lawrence Catholic School to use trusted third-party services that track this information or as necessary for service providers acting on our behalf, with appropriate contractual safeguards and user notification.

Legal Explanation

The original text is inconsistent, implying no sharing while permitting third-party tracking. The revision clarifies permitted sharing, contractual safeguards, and user notice, reducing risk of deceptive practices claims.

3. Insufficient Opt-Out Mechanisms for Data Collection The policy provides an email unsubscribe link for communications but does not clearly explain how users can opt out of data collection or analytics tracking. Under CCPA and other privacy frameworks, failure to offer clear opt-out rights can result in statutory damages of $100–$750 per user, per incident.

Legal Analysis

medium Risk

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Email: PleaseTo opt out of communications or data collection, including analytics and tracking, users may use the unsubscribe link at the end of our email communications or contact us via the information belowdirectly. We honor all opt-out requests in accordance with CCPA and other applicable laws.

Legal Explanation

The original clause only covers email opt-outs, not broader data collection or analytics. The revision ensures compliance with CCPA opt-out requirements and reduces statutory damages risk.

4. Vague Security Safeguards and Liability Limitations The policy states that security measures are taken “to the best of our ability,” but lacks specific commitments or limitations of liability. In the event of a data breach, this vagueness could undermine enforceability and expose the school to costly litigation and reputational harm.

Legal Analysis

medium Risk

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To the best of our ability, we have taken the appropriateWe implement industry-standard security measures in place, including encryption and regular security audits, to protect against the losspersonal data. However, misuse or alteration of information that we have collected from you atdisclaim liability for breaches beyond our websitereasonable control, except as required by law.

Legal Explanation

The original clause is vague and lacks enforceable limitations of liability. The revision specifies security standards and clarifies liability, reducing litigation exposure.

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Conclusion: Proactive Legal Protection is Essential Our examination shows that even well-intentioned privacy policies can harbor costly legal risks. Addressing these issues not only strengthens compliance with GDPR, CCPA, and U.S. consumer protection laws, but also reduces the likelihood of regulatory fines, lawsuits, and reputational loss.

Are your contracts and policies truly airtight? What would a single regulatory audit reveal about your risk exposure? How much could you save by proactively redlining your legal documents?

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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.