If you are not there yet, do not worry. In 1999, only 10% of the web sites surveyed by Dr. Mary J. Culnan, for the Georgetown Internet Privacy Policy Study, addressed all four areas recommended by the FTC (Culnan 1999). The FTC resurveyed sites again in 2000, and only 20% of the web sites that they surveyed addressed all four of the suggested areas (FTC 2000). For those of us not in the financial industries or with users under 13 years of age, these concepts may be only suggestions. If you are in one of those industries, they are the law. If you have not already done so, consult your legal advisor for a complete review of the laws and what you must do to comply with them. A great resource for privacy issues exists in organizations that certify and audit privacy policies. You should consider obtaining a certification from one or more of these organizations to show your users that you take their privacy seriously. TRUSTe, the Better Business Bureau and KPMG all provide certification programs.
As important to your users as having a privacy policy is adhering to it. The Georgetown Health Privacy Project "released a study on Feb. 1 showing that many online health sites don't follow their own privacy policies." (Green 2000). It is crucial that you set in place practices that will uphold the policy that you set forth. If you say that you will not share user information with business partners, do not. If you say that you will not use the e-mail address that you collect for cross marketing, do not. If you say that you will keep the users information safe and secure, make sure that you have regular audits of your security to make sure that you do. Do what you say you will, and you will be in great shape.
If you follow these guidelines, addressing Notice, Choice, Access and Security, you are well on the way to creating a privacy policy for your site. I want to conclude by saying that I am a techie, not a lawyer, so please do not confuse the ideas in this article with legal advice. It is not an authoritative coverage of a complex topic. So, take it for what it is; a call to all web professionals to examine their privacy policies. If you have not done so, it may be appropriate to seek legal counsel to make sure that any policy that you implement is not only fair and useful, but also legal.
Ken Wilson has over 15 years of IT experience, primarily in the legal and financial industries. For the past several years his focus has been on Internet Development, building systems for dotcoms such as Juniper Financial and Bill-Me-Later.com and is currently hard at work on an Investor Portal for Deutsche Bank. Ken is a Senior Architect at Kaloke Technologies, Inc. and a Product Manager for their successful KWML framework.