14.1 About Privacy Policies
Introduction:
A good privacy notice is easy to find, easy to read, and comprehensively explains all your online information practices. It also provides online visitors an opportunity to make informed decisions about the collection and use of their information. As part of good business practices, posting a notice is an important first step in defining your online policies and towards answering one of the major concerns (and barriers) voiced by web- users when going online.
A privacy notice is also a promise. As a promise, it is not enough to simply post such a notice. To effectively promote trust and confidence in you and your website, the provisions of a privacy notice must also be fully implemented as part of a larger privacy policy. Careful consideration should therefore go into the creation of a notice so it accurately reflects your own unique information practices and you can guarantee a faithful adherence to its provisions.
For these reasons, the following sample privacy notice is held out only as a drafting aid, and not necessarily an absolute definition of an acceptable privacy notice. You should also note that many of the BBBOnLine privacy notice requirements turn on particular information practices. Should any of these information practices be utilized, an applicant's privacy notice will need to contain additional disclosures as required by the BBB On-Line Privacy Program.
The following sample privacy notice describes basic information practices for a single website directed to U.S. residents. Additional disclosures would be required for website operators that:
  • limit the application of the privacy notice to U.S. residents,
  • share individually identifiable information collected online with unaffiliated third parties or corporate affiliates not governed by the same privacy policy,
  • direct part of their website to children or collect information from online visitors actually known to be children,
  • enhance or merge individually identifiable information or prospect information collected online with data from third parties for the purposes of marketing products or services to the subject of that information,
  • apply the privacy notice provisions to everyone except those operating solely in a business capacity,
  • limit the scope of the BBBOnLine privacy seal by excluding in the application corporate subsidiaries, operating divisions, or websites devoted to other discrete product lines,
  • condition access to any part of the website on the disclosure of individually identifiable information,
  • allow other organizations to collect individually identifiable information or prospect information by interacting directly with online visitors at the applicant's website,
  • collect passive information (including cookie information) that is linked to a name or similarly specific identifier,
  • use prospect information for any purpose other than those for which the information was submitted, or
  • limit access to maintained individually identifiable information or prospect information by limiting the frequency of requests or by requiring a processing fee; or limit access due to an inability to retrieve such information in the ordinary course of business.
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