- Transparency. When putting this policy together keep in mind that a clear policy helps build trust. Identify clearly its scope (e.g., “the website at www.XYZ”). Do not make statements you may not adhere to (like “we will not share your data,” if there may be instances where you want or have to share the data, such as mergers and acquisitions or as required by law). If your site gathers data via cookies, say so. Provide specific examples of what may or may not be done with the data collected. Similarly, notify customers of updates. Customers realize that you may need to update the policy from time to time. Proactively reach out with an email or letter to let them know of any material changes.
- Don’t Copy and Paste! While it may be tempting to use a policy already posted by another company, if the policy you post is not in line with your practices, it may be considered unfair and deceptive trade practice, actionable by the FTC and potentially subject to class action litigation. It is prudent to delegate the task of drafting a policy to professionals. Those with experience drafting these policies can better ensure you get one that meets your needs while protecting your business’ interests.
Businesses looking for comprehensive legal counsel and oversight of online privacy and data security issues can trust Calfee, with locations in Ohio, Washington D.C., Indianapolis and New York as well as globally through the Lex Mundi legal network.
Calfee Connections blogs, vlogs and other educational content are intended to inform and educate readers about legal developments and are not intended as legal advice for any specific individual or specific situation. Please consult with your attorney regarding any legal questions you may have. With regard to all content including case studies or descriptions, past outcomes do not predict future results. The opinions expressed may not necessarily reflect the view points of all attorneys and professionals of Calfee, Halter & Griswold LLP or its subsidiary. Updates related to all COVID-19 government assistance programs are provided with the most current information made available to Calfee at the time of publication. Clarifications and further guidance are being disseminated from government authorities on an ongoing basis. All information should be reaffirmed prior to the submission of any application and/or program participation.
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