David Rodriguez

David Rodriguez

I am Assistant Professor and hold a Ph.D. in Privacy Engineering at the Universidad Politécnica de Madrid (UPM), specializing in Privacy and Data Protection.

Overcoming Language Barriers: Multilingual Analysis of the Impact of a 2023 Swiss Privacy Law Revision

Published in Proceedings on Privacy Enhancing Technologies, 2026(4), 2026

Abstract

Policymakers enact and revise privacy laws expecting meaningful benefits for citizens, yet empirical evidence of real-world impact remains limited outside heavily studied jurisdictions such as the EU and California. This paper analyzes whether Switzerland’s 2023 revision of the Federal Act on Data Protection affected privacy policy disclosures on Swiss-facing websites.

To address Switzerland’s multilingual setting, the paper develops an LLM-based pipeline that extracts legally relevant disclosure labels from German, French, Italian, and English privacy policies without requiring translation. On a benchmark of 120 expert-annotated privacy policies, the pipeline achieves F1 scores above 0.90 for most language and disclosure-dimension pairs.

Applying the method to privacy policies collected from more than 35,000 Swiss- and EU-facing websites before and after the 2023 reform, the study finds significant increases in both mandatory and voluntary disclosures of data subject rights among Swiss privacy policies. The analysis also identifies widespread use of automated privacy policy generators, which are associated with disclosure-rate increases of up to 15%.

Key Contributions

  • Provides large-scale empirical evidence on the real-world effects of Switzerland’s 2023 privacy law reform.
  • Develops and validates a multilingual LLM-based pipeline for privacy policy disclosure assessment across German, French, Italian, and English.
  • Introduces an expert-annotated benchmark dataset of 120 multilingual privacy policies.
  • Analyzes more than 35,000 Swiss- and EU-facing websites before and after the reform.
  • Shows that automated privacy policy generators are widely used and associated with higher disclosure rates.

👉 Read the preprint

Recommended citation: L. Nenadic, D. Rodriguez, J.A. Calandrino. "Overcoming Language Barriers: Multilingual Analysis of the Impact of a 2023 Swiss Privacy Law Revision." Proceedings on Privacy Enhancing Technologies, 2026(4).
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