Layered Data: how to properly apply it for GDPR compliance

Layered data in data protection safeguards user rights under applicable regulations. The arrangement of information should be structured into two...
14 November 2023

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Layered Data: how to properly apply it for GDPR compliance

Layered data in data protection safeguards user rights under applicable regulations. The arrangement of information should be structured into two levels: a first layer with basic information and a more detailed second layer that should be linked to facilitate access to the user’s data. 

To enhance content comprehension, the headings should use simple, clear, and concise language

In this article, you will learn how to apply layered data to comply with the General Data Protection Regulation (GDPR).

What Is Layered Data?

Layered data in data protection is a requirement of the General Data Protection Regulation (GDPR) whereby information provided to citizens regarding the processing of their data must be organized into two interconnected layers.

These layers are as follows:

  1. First layer: Contains basic, structured, and concise information.
  2. Second layer: Includes much more detailed information.

The objectives of this arrangement are:

  • Facilitating the design of procedures and forms for Data Processing Controllers.
  • Ensuring that interested individuals can access the most relevant information quickly, efficiently, and in a simplified manner.
Layered Data: how to properly apply it for GDPR compliance

Benefits of Layered Data for GDPR Compliance

Implementing a layered data approach can offer numerous benefits when it comes to achieving GDPR compliance. Let’s explore the advantages of using layered data to adhere to the General Data Protection Regulation (GDPR):

Improved User Understanding

Layered data ensures that individuals can access information about how their data is processed in a clear and concise manner. By presenting information in easily digestible layers, users are more likely to comprehend their rights and how their data is being handled.

Enhanced Transparency

Transparency is a fundamental principle of GDPR. Layered data allows organizations to provide detailed information about data processing while keeping the initial layer concise. This transparency fosters trust with users, as they can easily access the information they need to make informed decisions about their data.

Customized Access

Layered data provides users with the flexibility to explore the level of detail they desire. They can start with the basic information in the first layer and then access more in-depth details from the second layer if needed. This customization ensures that users can tailor their data protection journey according to their preferences.

Legal Compliance

Meeting the requirements of GDPR is essential to avoid legal consequences. Layered data helps organizations comply with GDPR’s transparency and information provision requirements, reducing the risk of fines and penalties for non-compliance.

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Efficient Communication

Layered data allows organizations to communicate complex data processing concepts more effectively. By breaking down information into manageable layers, organizations can avoid overwhelming users with too much detail at once.

User Empowerment

Empowering users to understand and control their data is a key aspect of GDPR. Layered data enables users to exercise their rights, such as the right to access, rectify, or delete their data, with greater ease. This empowerment enhances user trust and satisfaction.


Layered data is adaptable to the needs of different organizations and industries. Whether you are a small business or a large corporation, you can implement layered data structures that suit your specific data processing requirements.

User-Friendly Design

The layered approach encourages the use of plain language and user-friendly design principles. This ensures that even individuals who are not well-versed in legal or technical terminology can access and understand the information provided.

Benefits of Layered Data for GDPR Compliance

Reduced Information Overload

GDPR compliance often involves sharing a substantial amount of information. Layered data helps prevent information overload by allowing users to access details gradually, focusing on what is most relevant to them.

Positive User Experience

By offering a structured and user-centric approach to data protection information, layered data contributes to an overall positive user experience. Users are more likely to engage positively with organizations that prioritize their privacy and provide accessible information.

In summary, implementing a layered data approach for GDPR compliance not only ensures legal conformity but also enhances user trust, understanding, and control over their personal data. It is a win-win strategy that benefits both organizations and individuals in the data-driven digital landscape.

First Layer: Basic Information

Regarding the first layer of information, it should be headed by the title “Basic Information on Data Protection,” and it must contain the following sections:

  • Data Controller: In this section, you should specify the legal entity or natural person responsible for data, both for collection and processing.
  • Purpose of Data Collection: It is necessary to specify the purpose for which you are requesting data, explaining why you need it.
  • Legal Basis: At this point, you should state the legal basis described in GDPR on which you rely for data collection. This can include:

– Contract execution.

– Compliance with a legal obligation.

– Public interest mission.

– Exercise of public authority.

– Legitimate interests of the Controller or a third party.

– Consent of the data subject.

If the legal basis is based on multiple purposes, you should highlight the primary one.

  • Recipients: This section must specify whether the information is shared with third parties. If so, the details should be provided.
  • Rights: The rights of access, rectification, and deletion of data must be explicitly stated, along with information about how and where they can be exercised.
  • Additional Information: It is essential to facilitate access to additional information from the second layer through a link. According to the Spanish Data Protection Agency (AEPD), presenting this information in tabular form is advisable to make it easily accessible in a single field of vision.
First Layer: Basic Information

Second Layer: Additional Information

The second layer should detail the information contained in the first layer and complement it with all the necessary data, using the same headings.

Recommendations for Drafting Additional Information in the Second Layer

As a guideline, remember to use simple language, avoiding ambiguities and legal jargon that may confuse those unfamiliar with the field. Here are some additional guidelines:

  • Expand on the information provided in the first layer by detailing users’ rights regarding their data. For example, in the case of the data controller, provide not only identification but also contact information if representatives exist, and so on.
  • Remember that each section’s length and subheadings depend on the complexity of your own activities.
  • You can add a section on best practices and philosophy, which, although not required by GDPR, reinforces your commitment to transparency and builds trust.

Both the first and second layers should be related so that individuals can access sufficient information to protect their rights under GDPR.

As you have seen throughout this article, the layered data approach of GDPR ensures the respect of individuals’ digital privacy, just as we do with our proctoring plans at Smowltech. 

Thanks to our software, you can have secure environments for your remote tests and evaluations with all the necessary legal guarantees. Discover it by requesting a free demo today.

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