The Blurred Boundary between Drafting and Translating in the EU: Accessibility and Genre in GDPR Privacy Notices through the Lens of ISO 24495-2

GDPR privacy notices constitute a stable supranational legal genre with a recurrent, legally prescribed communicative purpose and predictable macro-structure. Under Article 12 GDPR, they must be concise, transparent, intelligible and easily accessible, using clear and plain language. Against this background, and within a functional and genre-based approach, this contribution examines privacy notices as a point of intersection between accessibility and legal translation, understood here in intralingual terms. Drawing on a qualitative analysis of six European university privacy notices, the paper applies Principles 2 and 3 of ISO 24495-2:2025, concerning findability and understandability, and supplements them with a genre-based dimension of procedural actionability. The findings suggest that accessibility in GDPR privacy notices is neither absolute nor purely linguistic. Rather, it takes the form of bounded accessibility, emerging from the interaction between legal effect, genre conventions, institutional voice and reader-oriented message design.