Quoting from the beginning of the publication’s Executive Summary [emphasis added]:
The Executive Summary includes the following Highlights of Recommendations:
- Use plain, straightforward language. Avoid technical or legal jargon.
- Use a format that makes the policy readable, such as a layered format.
Online Tracking/Do Not Track
- Make it easy for a consumer to find the section in which you describe your policy regarding online tracking by labeling it, for example: “How We Respond to Do Not Track Signals,” “Online Tracking” or “California Do Not Track Disclosures.”
- Describe how you respond to a browser’s Do Not Track signal or to other such mechanisms. This is more transparent than linking to a “choice program.”
- State whether other parties are or may be collecting personally identifiable information of consumers while they are on your site or service.
Data Use and Sharing
- Explain your uses of personally identifiable information beyond what is necessary for fulfilling a customer transaction or for the basic functionality of an online service.
- Whenever possible, provide a link to the privacy policies of third parties with whom you share personally identifiable information.
Individual Choice and Access
- Describe the choices a consumer has regarding the collection, use and sharing of his or her personal information.
- Tell your customers whom they can contact with questions or concerns about your privacy policies and practices.
- Privacy on the Go – California Attorney General Publishes Recommendations
Dana H. Shultz, Attorney at Law +1 510 547-0545 dana [at] danashultz [dot] com
This blog does not provide legal advice and does not create an attorney-client relationship. If you need legal advice, please contact a lawyer directly.