Earlier this year, I
reported that the Office of the Privacy Commissioner of Canada
(OPC) was participating in the first ever Internet sweep by the
Global Privacy Enforcement Network (GPEN).
The results are in. If you haven't dusted off your privacy
policy for a thorough clean-up, you should.
Yesterday, the OPC reported that globally the GPEN found that
almost a quarter of the 2,276 mobile Apps and websites examined did
policies that could be found raised concerns regarding the
relevance of the information. In particular policies:
used boilerplate language with brief over-generalized
failed to provide information customized to describe the
failed to take into account the relevant regulatory
directly quoted legislation rather than informing users
In addition, the OPC reported the initial results of its
own examination of 300 websites. Among the findings were:
Of those with privacy policies, 1 in 10 buried them in other
documents such as Terms and Conditions or had policies that were
otherwise hard to find
2 in 10 failed to provide a contact or made the contact
information for the privacy officer difficult to find
2 in 10 failed to provide relevant information – in some
cases merely quoting the legislation or the Fair Information
Among the recommendations:
"user-centric" privacy notices
Make the policy comprehensive – covering online and
Explain directly the points of contact during which information
will be collected
Explain what is collected and how it is used
Provide detailed explanation of website personalization
features and how to opt-out
Provide a method of reporting privacy breaches
The OPC's news release and related background information
can be found here.
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