AI-enabled Automation for Completeness Checking of Privacy Policies
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Abstract (arXiv)
Technological advances in information sharing have raised concerns about data protection. Privacy policies contain privacy-related requirements about how the personal data of individuals will be handled by an organization or a software system (e.g., a web service or an app). In Europe, privacy policies are subject to compliance with the General Data Protection Regulation (GDPR). A prerequisite for GDPR compliance checking is to verify whether the content of a privacy policy is complete according to the provisions of GDPR. Incomplete privacy policies might result in large fines on violating organization as well as incomplete privacy-related software specifications. Manual completeness checking is both time-consuming and error-prone. In this paper, we propose AI-based automation for the completeness checking of privacy policies. Through systematic qualitative methods, we first build two artifacts to characterize the privacy-related provisions of GDPR, namely a conceptual model and a set of completeness criteria. Then, we develop an automated solution on top of these artifacts by leveraging a combination of natural language processing and supervised machine learning. Specifically, we identify the GDPR-relevant information content in privacy policies and subsequently check them against the completeness criteria. To evaluate our approach, we collected 234 real privacy policies from the fund industry. Over a set of 48 unseen privacy policies, our approach detected 300 of the total of 334 violations of some completeness criteria correctly, while producing 23 false positives. The approach thus has a precision of 92.9% and recall of 89.8%. Compared to a baseline that applies keyword search only, our approach results in an improvement of 24.5% in precision and 38% in recall.
Key facts. Cited by 7 papers in the map (data through 7 Oct 2026). Builds on 14 of its 79 references that are in the map. First posted on arXiv 10 Jun 2021.
Builds on
14 of 79 references.
References · 14
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Built on by
Citing papers per year: 2023: 3; 2024: 2; 2025: 1; 2026: 1.
7 papers.
- 2024Enhancing Legal Compliance and Regulation Analysis with Large Language Modelscited by 10
- 2025Helping Johnny Make Sense of Privacy Policies with LLMscited by 5
- 2023A Multi-solution Study on GDPR AI-enabled Completeness Checking of DPAscited by 3
- 2023A Human-in-the-Loop Approach for Information Extraction from Privacy Policies under Data Scarcitycited by 2
- 2023Legal Requirements Analysiscited by 2
- 2024Legally Binding but Unfair? Towards Assessing Fairness of Privacy Policiescited by 1
- 2026Privacy Washing: Detecting Internal Contradictions in Privacy Policiescited by 0
- 2026Privacy Washing: Detecting Internal Contradictions in Privacy Policies2 Sep 2026
- 2025Helping Johnny Make Sense of Privacy Policies with LLMs27 Jan 2025
- 2024Enhancing Legal Compliance and Regulation Analysis with Large Language Models26 Apr 2024
- 2024Legally Binding but Unfair? Towards Assessing Fairness of Privacy Policies12 Mar 2024
- 2023A Multi-solution Study on GDPR AI-enabled Completeness Checking of DPAs23 Nov 2023
- 2023Legal Requirements Analysis23 Nov 2023
- 2023A Human-in-the-Loop Approach for Information Extraction from Privacy Policies under Data Scarcity24 May 2023