Additional Information to Include
- Directions for customers to access and update data (e.g., password resets, contact information updates, and mechanisms for unsubscribing)
- Contact details or other means of reaching persons in your organization that can address user queries or concerns
When disclosing the foregoing information, you should be as specific as possible and avoid industry “jargon” as much as reasonably possible. As noted in the New York Times article cited in Part 1 of this Contract Corner (opinion piece), privacy policies of the past have been ineffective for communicating to the average user, as they can be incredibly difficult to understand. Especially if your site or application has any special requirements for collecting information from minors, you need to state them in an easy to read manner.
Reviewing and Updating the Policy/Flexibility
In this Part 2 of our Contract Corner on Privacy Policies, we have provided some tips on drafting an effective policy. Please be on the lookout for future posts in Sourcing @ Morgan Lewis that update the legal landscape for privacy issues and provide drafting pointers for policies.