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Creating a Good Privacy Policy
by David Crispi, Director of ISP Relations
Having a good privacy policy is one of the top priorities of e-marketing today. Consumers want to know that their privacy is protected when they interact and do business with you. Your Privacy Policy is what assures them that you are legitimate, honest, and someone they, in fact, do want to do business with.
A sound Privacy Policy that is posted on your web site with the practices you adhere to within your electronic communications protects not only your customers and prospects, but your company as well.
So, how do you make sure your policy is up to par?
1. Find out what is standard practice and acceptable for your industry.
There are many standards for setting up Privacy Policies, so start out by doing your research and finding out what others in your industry are doing. For IMN, an organization that often sets policy for our industry is the Network Advertising Initiative (NAI). They have worked extensively with the Federal Trade Commission to set up privacy principles that they hope will be widely accepted. As a member of this organization, I continually review what they are doing and incorporate their recommendations as appropriate into IMN’s policies.
2. Review various policies and decide what topics are important to your company.
The Online Privacy Alliance has an excellent brochure called “Creating consumer confidence online: Five Essential Elements to Online Privacy.” This brochure covers all of the major points including why you should have a policy, what you should disclose regarding the information you collect, how that information will be used, and what the consequences are if an individual refuses to provide what is being requested. The brochure also discusses data security and data quality. The Alliance’s web site also has suggested principals to follow for collecting information from children under age 13.
3. Write up your own policy and include how you collect your data.
Now that you have some general guidelines, it’s time to write up your own Privacy Policy. One key point that is sometimes overlooked is that it is important to tell your subscribers how you collect data from them. This includes outlining within the Policy exactly what data collection features you use. For instance, if you utilize cookies and web beacons on your company’s website, be upfront about this. Clearly describe how these tools are being used, what information they are capturing, and how you will be using that information.
4. Get a legal blessing.
Once you have written up your policy, have your legal department review it. If your lawyer is happy, chances are you’ve said what you’ve needed to say.
5. Check your policy often.
Don’t publish your policy once and let it hang out there forever. Keep on top of the news on this topic and check your policy often to ensure that it is up to date at all times.
Remember, a Privacy Policy protects your subscribers, but by having a sound policy that is clearly visible on your site and everywhere you collect customer and prospect information, you are also protecting your company.
I recently updated IMN’s policy by using the principals I have outlined above. Feel free to take a look at our policy and use it as part of your research! And if you have any other questions, email me at dcrispi@imninc.com.
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