Most policy generators do template substitution — they take a fixed text file with placeholders and swap in your company name, your email, your country. miniterms does not. Understanding the difference is the difference between a policy that survives an AEPD inquiry and one that does not.
Mode B render in one paragraph
Mode B is the internal name for the engine. Instead of starting from a finished policy and filling holes, it starts from your business profile and the jurisdiction's regulator citation set — the list of articles, BOE entries, EDPB guidelines, and AEPD circulars that apply to a controller in your situation. It walks that set, clause by clause, and emits the text that each citation requires. The output is a document where every paragraph traces back to a specific named regulatory source.
Why this matters legally
A template-filled policy is, at best, evidence that you bought a template. A Mode B-rendered policy is evidence that you considered each specific obligation a regulator imposes on a controller in your jurisdiction and processing posture, and addressed it in writing. The distinction shows up in two places that matter:
- Accountability principle — [GDPR art. 5(2)] requires you to be able to demonstrate compliance, not merely claim it. Inline citations are a demonstration artifact.
- AEPD inspections — when the AEPD opens a complaint procedure (procedimiento sancionador), the first request is for documentation showing which sources informed your policy. Mode B output answers that request directly.
What you see in the output
A typical generated paragraph looks like this in your HTML preview:
The controller will keep your account data for as long as your account is active, and for one additional year after closure for billing and tax reasons.
[GDPR art. 5(1)(e)][BOE LOPDGDP art. 32]
The bracketed citations are real article references. They link out to the canonical source — eur-lex.europa.eu for the GDPR, boe.es for Spanish law, edpb.europa.eu for EDPB guidelines.
What Mode B does NOT do
- It does not invent retention periods you didn't specify. If your profile says you keep billing data for six years (Spain's general accounting law minimum), it cites that. If you don't specify, the engine uses the regulator's stated minimum and flags the clause for your review.
- It does not write legal opinions. It surfaces obligations and applies your declared facts to them.
- It does not replace counsel. The generated document is a defensible starting point, not a substitute for review by a Spanish data protection lawyer if your processing is high-risk.
What changes when regulators publish updates
When the AEPD issues a new circular, or when the EDPB updates guideline 03/2020 to a new version, miniterms updates the citation set. Your already-generated policy keeps working — but you will see a banner in the dashboard suggesting you regenerate to pick up the change. See Regenerating when the law changes.
miniterms output is a documentation artifact. It is not legal advice. Have a qualified data protection lawyer review the generated documents before publication if your processing is high-risk.