The Importance of Privacy and Consumer Accountability
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- Susan Perry
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1 Innovations in Online Privacy Solutions for Small Businesses New Scanning Technologies Improved Disclosures Enhanced Consumer Participation 4 November 2009
2 Consumers Today Want to Participate 1
3 New Consumer Endorsement Options Between August 20 th, 2009 and September 30 th, 2009 consumers made 236,716 positive endorsements of our clients privacy practices. 2
4 TRUSTe Company Overview CONSUMERS Look to Identify Trustworthy Online Businesses BUSINESSES Need to Demonstrate Compliance with Privacy Best Practices to Gain Consumer Trust REGULATORS Want Enforcement and Compliance Assurance 3
5 TRUSTe Company Overview Mission: Build Privacy and Trust for the Networked World 1997: Founded in San Francisco, California, Launched Web Privacy Seal 2001: Launched EU Safe Harbor Seal; Largest Program 2005: Launched Trusted Download Program 2008: Raised capital and changed structure for growth, technology, and emerging issues TRUSTe certified web sites Trusted guidepost for consumers millions see seals and verify TRUSTecertified companies each month 2009: Acquired malicious content detection and expansive monitoring capabilities 4
6 Tech Leading Customers Health Consumer Brands Portal Financial Telecom 5
7 There Are Millions of Small Businesses Worldwide There are 27 million small businesses in the US alone 1. One-third of US SMBs currently sell products online or use e-commerce as a business tool. Another 26 percent said they plan to follow suit by the end of Within the next year, the majority of SMBs will become e-commerce companies 2. 6
8 SMB Privacy Issues Privacy Policy? Is it consistent with data collection practices? Does Home Page link to Privacy Policy? Does Privacy Policy have an effective date? Does Privacy Policy have clear contact information for consumer questions? Has the Privacy Policy been reviewed in the last Year? 7
9 TRUSTe s New Small Business Product Line Target: Small Companies Simpler privacy challenges (not sharing PII with 3 rd Parties) Products: Basic Privacy Policy TRUSTe Privacy Seal Key Attributes Accessible Distributable Lower Price Point Fast-Turnaround 8
10 Overview of SMB TRUSTe Services 9
11 SMB Certification Process 10
12 Site Scanning: Legitimacy, Security, and Risk Privacy Links to privacy statement Tracking technologies used on the site Location PII collections Reputation DNS Authority Whois Information Security Malware Detection Presence of SSL Certificate Issuer 11
13 Display of the TRUSTe Seal 12
14 Generated Privacy Statement Served by TRUSTe 13
15 Demonstrating Adherence to TRUSTe Requirements SMB Program Requirements Accurate Privacy Policy Simpler Privacy Practices (no 3 rd party sharing) TRUSTe Dispute Resolution Program Security: SSL, No Malware Detected, Positive Reputation 14
16 Client Testimonial: Consumer Safety Plus Sales I m looking for ways to get ahead of the competition and increase sales, and one of the ways I m doing that is by managing my Web site s reputation. TRUSTe is a great option for me as an entrepreneur with a limited budget, I ve never had an IT consultant or an in-house lawyer they walked me through what I needed to do to make my Web site in compliance and my customers safe. - Justin Severidt, DiscountFlea.com 15
17 Consumers Reward Good Privacy 16
18 Additional Consumer Assurance 17
19 Addressing Online Behavioral Advertising Improving Consumer Disclosures & Choices Your Ads & Info 18
20 Opt Out Choices ** We are working with TRUSTe to test improved consumer advertising notices.** Notice Opt-Out Choices Learn More Leave Feedback File Complaint Reminder Opt-Out Choices Opt-Out of All Listed Advertising Networks: [ see all 95 networks ] Opt-Out All About Behavioral Advertising Opt-Out When you opt-out of behavioral advertising, the unique ad tracking cookie used by each ad network is replaced by an opt-out cookie. The ad network will no longer tailor advertising to you based on your previous website visits. If the opt-out cookie is deleted, you will need to opt out again using this tool. If you use more than one browser or more than one computer, you will need to opt out for each of them. We can send you a regular reminder to maintain your opt-out choices. Tell us what you think. 19
21 More Information TRUSTe Program Requirements TRUSTe Blog Twitter: Facebook Fan Page: LinkedIn Group: Maureen Cooney, VP Policy and CPO Thank You Fran Maier, CEO 20
22 Improving Privacy Policies 21
23 Privacy Complaint Volume Total Complaints Licensee-Related Complaints
24 EU Complaint Volume Seal Holders 41 Seal Holders 138 Seal Holders 23
25 2009 Privacy Complaint Categories 24
26 And when seal holders won t comply 25
27 We Take Action 2009 Enforcement Actions to Date 2 Licensees Terminated for Cause Failure to offer opt-out requirement Unauthorized sale of prescription medication 2 Licensees Suspended: unsubscribe violation Unintentional distribution of malware via third-party ads 26
28 TRUSTe: Largest EU Safe Harbor Program Launched in EU Safe Harbor seal holders display the EU seal on hundreds of licensed websites. 27
29 TRUSTe: APEC Accountability Agent for the U.S. TRUSTe oversaw testing to evaluate a cross-border privacy accountability process Participating Companies 28
30 APEC Privacy Framework Testing Pilot Program Reviewed company privacy policies & website practices Evaluated testing documents ability to assess a company s alignment with APEC Privacy Principles Findings All the privacy policies and representations of practices were consistent with APEC Privacy Principles The documents alone could not verify a company s actual practices and consistency with a company s privacy promises and representations Next Steps: Working with APEC s Electronic Commerce Steering Group Improving assessments and other documents to measure company practices for crossborder data flows. 29
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