Policy development · SaaS & technology
Privacy & Security Policy Development for Martech & Adtech Platforms
A martech or adtech platform needs policies that answer questions a generic privacy-policy template never anticipates: how long a behavioural segment may be kept, what a CRTC investigator expects a CASL compliance program to look like, and what a DSP has to disclose about where bid data goes next. We draft that specific set, in the wording your product and legal teams can actually defend, rather than adapting boilerplate written for a retail website.
Reviewed by the Privacy Horizon team · Last reviewed
What you're protecting
What these policies have to get right
The documents worth writing well here are the ones a regulator, a brand vendor reviewer or a Quebec user will actually read.
Consent capture and wording
The exact language shown at the point of collection, since it determines whether a later consent claim is express, implied, or unsupportable.
Retention schedules for pseudonymous data
Defined lifespans for identifiers, clickstream and segment data, so behavioural information does not sit indefinitely with no documented reason to keep it.
Sub-processor and downstream-sharing disclosure
A clear list of who receives matched or enriched data, covering the platforms, clean rooms and data suppliers your product actually integrates with.
Quebec-specific notices and defaults
Plain-language, bilingual-ready text describing tracking and profiling functions, matched to the default-off state those functions must actually ship in.
CASL compliance program documentation
Written procedures covering consent capture, unsubscribe handling and record-keeping, the kind of program the CRTC looks for when assessing whether a violation was a one-off or a pattern.
Regulatory map
The standards this policy set has to satisfy
Each regime expects something specific in writing, not just a practice that happens to exist informally.
CASL sections 6, 10 and 11
Consent, sender identification and a working unsubscribe honoured within ten business days are statutory requirements that a written compliance program turns into a repeatable process.
Law 25's plain-language and impact-assessment duties
Privacy policies must be written in clear language, and a privacy impact assessment is required before a new system communicates personal information outside Quebec.
PIPEDA's openness principle
Organizations must make information about their privacy practices readily available and understandable, a standard that a DSP's privacy policy has to meet even though its actual data subjects rarely visit its website.
The OPC's notice conditions for behavioural advertising
Opt-out consent for targeting is only defensible with a notice that is clear and timely, which sets a specific bar for how a tracking disclosure has to be worded, not just where it appears.
What goes wrong
What happens without this documentation
Missing or generic policies rarely cause a problem on their own; they become the reason an existing problem cannot be defended.
A CASL complaint with no compliance program to point to
The CRTC's process treats a documented compliance program as evidence of good faith. Without one, a single complaint reads as a pattern rather than an isolated error.
Retention with no stated limit
Segment and identifier data kept indefinitely because no policy ever set an end date, turning a routine audit or vendor review into a longer conversation than it needed to be.
A DSP privacy policy silent on data flow
Generic language that never mentions bid streams, identity graphs or clean-room partners leaves the company unable to show, in writing, that its actual practices match what it discloses.
A Quebec notice that describes the wrong default
Text claiming a tracking feature requires opt-in when the shipped product still defaults it on, a gap that a CAI review or a customer's own audit will surface quickly.
Our policy development for martech & adtech platforms
What our policy development covers for a martech platform
Documents matched to how your product actually collects, matches and shares data, kept current as the product changes.
CASL compliance program policy
Written procedures for consent capture, identification, unsubscribe handling and record-keeping, structured the way the CRTC's guidance describes an effective compliance program.
Behavioural and pseudonymous-data retention policy
Defined retention periods and deletion procedures for cookies, hashed identifiers, clickstream and segment data, tied to the purpose each category actually serves.
A privacy policy built for your platform role
Whether you operate as a DSP, SSP, CDP or ESP, the policy names your role plainly and discloses the downstream sharing that role involves.
Quebec-ready notices and consent text
Plain-language descriptions of tracking, location and profiling functions, matched to the default-off state those functions must ship in for Quebec users.
Vendor and sub-processor documentation
A maintained list of downstream platforms, clean rooms and data suppliers, and the contractual terms governing what they may do with matched data.
Ongoing updates as regulation and product evolve
Scheduled review as CASL guidance, Law 25 interpretation or your own product roadmap shifts, so the documentation never quietly falls out of date.
How the engagement runs
How we build the policy set
Grounded in what your systems actually do before a word gets drafted.
Step 1
Map the data flows
Walk through your pixels, SDKs, CDP connections and downstream partners to understand what is collected, matched and shared before writing anything.
Step 2
Draft against the regulatory checklist
Policies written to satisfy CASL, Law 25 and PIPEDA requirements specifically, using language your product and legal teams recognize as accurate.
Step 3
Review with product and engineering
Confirm the policy describes what is actually shipped, including current default states for tracking and profiling functions.
Step 4
Publish, train and schedule updates
Roll the documents out with a short briefing for the teams who rely on them, and set a review cadence tied to product releases.
What it costs
Cost drivers for martech policy work
Price follows the shape of the set: how many distinct products or platform roles need their own policy, how many jurisdictions your traffic touches, whether Quebec-facing work requires bilingual, Law 25-aligned material, and how much existing documentation can be updated rather than rewritten.
Policy development is a core component of our Virtual Privacy Office retainer and is also available as a standalone project. We recommend the most economical honest route once we have seen what you already have.
Martech & Adtech Platforms: Policy development questions, answered
The CRTC's guidance points to documented consent-capture procedures, a process for verifying sender identification on every message, an unsubscribe mechanism that takes effect within ten business days, staff training, and a record-keeping system that can reconstruct the consent history for any recipient on request. A program that exists only informally is difficult to defend once a complaint arrives.
There is no single statutory number, but PIPEDA's retention principle requires that personal information be kept only as long as necessary for the identified purpose, and Law 25 expects the same discipline. In practice this means setting explicit retention periods for identifiers, clickstream and segment data by category and purpose, then automating deletion rather than relying on someone remembering to do it.
It should plainly name your role in the ad-tech chain, describe the categories of data you receive from partners and clients, disclose the platforms and data suppliers you share matched or enriched data with, state retention periods, and explain how individuals or the businesses that supplied the data can raise questions. Generic consumer-facing language rarely covers any of this.
Neither exclusively; the policy should reflect what your actual practices require. Express consent language belongs wherever data use is sensitive or outside reasonable expectations, following the OPC's meaningful-consent guidance, while implied consent under an existing business relationship can cover narrower, expected uses within CASL's defined time windows.
At minimum annually, and immediately after any change that alters what data a product collects, how long it is kept, or who it is shared with. A policy that still describes last year's default settings is a liability the moment a customer or regulator compares it against what the product actually does today.
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