C.3. Privacy Self-Assessment

This privacy self-assessment has been used by XYZ and many other clients to help them formulate their internal privacy policy as well as their online Privacy Notice. One person I ran into at a Direct Marketing conference a few months ago was nice enough to write in.

Thanks so much for the information. We just revised our web site and didn't really have a privacy policy [before]. This info[rmation] helped me to write one, and we should have it up and on our site in a few days. I think the structure and content of this information is very useful, informative, and easy to read and comprehend.

The questions in Table C-6 are those that this company used to create its online privacy notices in just a few days.

Table C-6. Privacy Self-Assessment
Framework Question Checklist
1. What is your company's overall privacy position? a. Do you capture and store any data about your customers that is personally identifiable (is linked to an individual person's identity)? ___ Yes ___ No (If your answer is no, you don't need to answer the rest of these questions.)
b. What is your company's overall position regarding the importance of your customers' privacy and the safety of their data?  
c. What is your company's overall position regarding appropriate uses of customer data and who can access it?  
d. What options do your customers have if they are not comfortable with your customer information practices?  
e. When was the last time that your privacy policy and/or privacy statement was modified?  
2. What do you collect and what do you do with data you collect (Notice)? a. What types of data does your company collect from or about your customers? Personal identification data:

___ Name

___ Street address

___ Phone (home, work, fax, cell)

___ E-mail

Sensitive data:

___ Credit cards

___ Bank and financial information

___ Social security number

___ Driver's license number

___ Medical data

___ Educational data

Transaction data

___Types of products

___Behavior (online activity, recency and frequency of purchase)

___Interests and preferences

___Feedback and complaints

___Service and support activity

___ Demographics and psychographics

___ Business employment data

___ Product ownership data

___ Credit and financial data
b. How do you use the information you collect from your customers? (Check all that apply.) ___ Only to complete the transaction itself

___To reach customers in case of recalls or other product/service issues

___To validate the warranty or service contract

___To personalize and improve the customer's experience at our web site

___To monitor and improve our web site performance
c. With whom do you share your customers' information? (Check all that apply.) ___Authorized individuals with business needs within our company

___Third parties who need the information to complete the transaction (e.g., a shipping company)

___ Third parties who offer products or services that we think would be of interest to the customer

___ We sell and/or lease our database to unrelated third-party organizations.
d. Does your company target children? ___Yes ___No.

If you answered yes, how do you meet COPPA requirements?

How do you ensure you have parental approval before accepting information from children under the age of 13?

What third-party data do you append to your customer data?

How do you ensure you have parental authorization to take a credit card number online?
e. Do you use cookies? ___Yes ___No

If you answered yes:

Can a customer turn them off? How?

What will happen to the customer's web site experience or other future interactions if he turns cookies off?
2. What kinds of Choice do you give customers about how you use their data? ___We don't give our customers any options; we just use the data any way we want to.

___We can't give our customers any guarantee; our data is not consolidated into a single database, and we can't control it all.

___We give a customer an option, and we never contact him for marketing purposes if he answered NO (opt-out).

___We give a customer an option, and we never contact him for marketing purposes unless he explicitly answered YES (opt-in).

___We use opt-in for e-mail, but not for our other types of marketing.
3. How to you give customers access to their data and allow them to correct its accuracy? a. How do you allow your customer to see what data you have collected? ___We allow the customer to review and access his personal information online.

___We send the customer a printed copy of the information we have captured and stored.

___We currently cannot give customers access to their personally identifiable information.

___We only allow access after validating the customer's security information.
b. How do you allow changes to be made to the customer's data? (Check all that apply.) ___We don't/can't change data in our customer databases.

___We allow the customer to update his information directly online.

___We (the company) make the changes requested by the customer.

___We only allow updates after validating his security information.
4. What kind of Security protection do you provide for to protect your customers' data? What do you do while data is traveling to your site over the Internet? ___ Identification data

___ Sensitive data

___ Transaction data
 What have you done to ensure the security of the data once it's inside the company (electronic and physical storage)?  
 What management practices have you set up to ensure physical safety and protection from unauthorized users?  
5. What is your position on oversight and providing an independent recourse for your customers? a. Do you have company contact information? What is it?  
 b. Do you monitor the site and respond to concerns? Who is responsible?  
 c. Have you received a third-party privacy seal? ___Yes ___No

If you answered yes:

Who was it awarded by?

You can contact them at:

For more information about customer privacy, refer to Chapter 22.

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