Whether embarking on a new venture or for the established corporation, utilizing front line principles is key to protecting your operation, reputation and investment from legal exposure. Michael Steck is primed to consult, draft and implement your company’s privacy notice and policy.
A privacy notice is a statement that reflects how an organization collects, uses, retains and discloses personal information. In particular, a privacy notice should detail the following:
- What kind of personal information is collected
- Description of how this information will be used by the company
- Describe how the information is transferred to a third party
- Provide instructions on how a user can modify or delete their personal information.
- Provide information on how visitors can opt-out of communications.
- Indicate the effective date, and how you notify visitors of changes to the policy
For websites that collect information from children under the age of 13, the Children’s Online Privacy and Protection Act (“COPPA”) has special matters that must be included in online privacy policies. In particular the Federal Trade Commission (“FTC”) indicates the following must be disclosed for websites that fall under the terms of the COPPA
- The name, address, telephone number, and email address of all operators collecting or maintaining personal information through the site or service (or, after listing all such operators, provide the contact information for one that will handle all inquiries from parents);
- A description of what information the operator collects from children, including whether the operator enables children to make their personal information publicly available, how the operator uses such information, and the operator’s disclosure practices for such information; and
- That the parent can review or have deleted the child’s personal information and refuse to permit its further collection or use, and state the procedures for doing so.