Overcoming Language Barriers: Multilingual Analysis of the 2023 Swiss Privacy Law's Impact

Abstract

Policymakers enact and revise privacy laws expecting meaningful benefits for their people in practice. While scholarship has measured the real-world impact of some privacy regulations-the EU and California most notably-limited empirical evidence exists for many of the more than 140 countries that have implemented some form of privacy legislation. Switzerland, a multilingual country bordered almost entirely by EU states, is one such example. This paper analyzes the extent to which a 2023 alignment of Swiss privacy law with EU privacy regulation affected website privacy policies in Switzerland. To address Switzerland's unique multilingual culture, we develop an LLM-based pipeline that extracts legally relevant information as document-level labels in a single inference without requiring translation. On a benchmark of 120 expert-annotated privacy policies in German, French, Italian, and English, our pipeline achieves F1 scores above 0.90 for most pairs of languages and legally relevant disclosures. Applying this pipeline to privacy policies we collected from more than 35,000 Swiss- and EU-facing websites before and after the 2023 privacy law revision, we find significant increases in both mandatory and voluntary disclosures of data subject rights among Swiss privacy policies. In exploring the mechanisms driving increased disclosure rates, we discover heavy use of automated privacy policy generators and find that generated policies are associated with up to 15 percentage points higher disclosure rates. These results provide large-scale empirical evidence of how regulatory change and novel drafting technologies impact the content of privacy policies in a unique multilingual environment.