Privacy Policy

Privacy policy

A privacy policy is a statement of how and why your company / website collects Personally Identifiable Information (PII), what it does with it, what choices the consumer has about how it is used, whether the consumer can access the information, and what you do to assure that the information is secure.

Other privacy concerns that a privacy policy should address are the use of cookies and/or web bugs, if any.

For a more detailed explanation on what a privacy policy is and possible legalities requiring you to have a privacy policy on your website, please refer to this Wikipdia article

For help in creating your own privacy policy, The Direct Marketing Association has some good advice as well as a free, online privacy policy generator.

Other references:

• Fair Information Practice Principles
• Network Advertising Initiative
• EFF - Best Practices for Online Service Providers
• BBBonline - Sample Privacy Notice
• Deceptive Trade Practices

Cookie policy

A cookie policy is usually part of the privacy policy. It's addressed within it's own section (normally a paragraph) which states what type of cookies are used: session, or persistent.

Your site should offer as few cookies as possible, preferably none. The more widgets, advertising, and other third-party intervention causes your site to drop more cookies on to your visitors computers. When you do use scripts, or browser bars, or social networking link "buttons", etc you should address these in your cookie policy and offer explicit links to the other privacy policies available on these outside sources.

When using third-party advertising such as Google or DoublClick, reference their usage and include the appropriate links. Google is just one example of many advertising sites.

• DoubleClick DART cookie
• Google Adsense
• Google Advertising and Privacy

Tracking

A cookie policy should also mention whether the site uses any third-party trackers: Google Analytics and Quantserve are two popular ones. Tracking may also be done by using web beacons (web bug, tracking bug, tracking pixel, pixel tag, 1×1 gif, clear gif) This should be explicitly mentioned in your privacy policy if your site uses this technology.

Local shared object (LSO)

local shared object (LSO) are also referred to as "zombie" or "super" cookies. They are part of Adobe Flash. Quoting from Adobe:

Local shared objects, sometimes referred to as "Flash cookies," are data files that can be created on your computer by the sites you visit. Shared objects are most often used to enhance your web-browsing experience. A website can write a cookie on your computer, and the next time you visit it will load that cookie and its information in a way that provides a more customized experience. For example, you may have asked a site to remember your login name. That information is stored in the cookie and retrieved on your next visit so that the website displays your name in the login field on the site.

The interesting thing about LSO's are that when you delete your cookie cache, the LSO is able to rewrite the cookie. This causes the LSO to be used not only for tracking, but for spyware as well. The only time your site should use Adobe Flash LSO's are when you have created Flash files (.SWF / .FLV) to share with your visitors and these local stored objects should not be abused with the intent on spying upon your site visitors.

A little more information may be found on: local shared object

COPPA

Children's Online Privacy Protection Act.

For sites hosted within the USA, or on US servers (when whois registration is private), it is required to adhere to COPPA and if so, it should also be referenced within your site's privacy policy.

Websites that are collecting information from children under the age of thirteen are required to comply with Federal Trade Commission ( FTC ) Children's Online Privacy Protection Act (COPPA).

International scope

This is an American law, however, the Federal Trade Commission has made it clear that the requirements of COPPA will apply to foreign-operated web sites [operators] if such sites "are directed to children in the U.S. or knowingly collect information from children in the U.S re: FTC Privacy Initiatives

• COPPA - Children's Online Privacy Protection Act : http://www.coppa.org/
• The Children's Online Privacy Protection Act : http://www.ftc.gov/privacy/privacyinitiatives/childrens.html
• COPPA FAQ's : http://www.ftc.gov/privacy/coppafaqs.shtm
• Wikipedia article

P3P

Platform for Privacy Preferences (P3P) : http://www.w3.org/P3P/

standards developed by the World Wide Web Consortium

How to

There is a How_To_Privacy_Policy that offers help in creating your own privacy policy.

WOT Forum

A few articles of interest:

• Privacy Lawsuit Targets Net Giants Over ‘Zombie’ Cookies
• Browser Fingerprints Threaten Privacy
• A Primer on Information Theory and Privacy
• Flash Cookies and Privacy

see also: Personally Identifiable Information (PII)