This is the most common question we get from web publishers. As explained in our FAQ, here’s how you can achieve a top Privacyscore of 100:
- Personal data won’t be conveyed to third-parties without the user’s permission. It’s typical and appropriate to make this statement in general terms, and follow it with a set of exceptions (like government requests). But if the policy is open ended (“exceptions include …”) without any limitation, we can’t score it as protective.
- A user’s request to delete personal data will be honored. Of course, there may be exceptions for transactional information or data relating to pending disputes, which we recognize in the privacyscore. But those shouldn’t be stated in a way that undermines the principle.
- Notice will be provided in the case of disclosure in legal process or government requests, where legally allowed. We also encourage you to state whether subpoenas are required before you disclose personal data, or whether you also respond to more informal requests.
- If service providers have access to personal data, their use should be restricted and confidential. This is a matter of reviewing contracts to confirm that confidentiality has been assured.
- All trackers seen on your site should meet the following requirements, on the face of their privacy policies:
- Personal data is not collected or used, or is always separated from behavioral data. We weight this factor heavily, given reasonable user expectation that tracking behavior across sites will not be individually identifiable.
- Boundaries are recognized in areas like health conditions and financial data. Currently, nearly any statement establishing sensitive boundaries suffices for scoring; although such statements do vary in strength. The strongest (and best) prevailing expression of boundaries comes from the rules for Google’s Certified Ad Network program (read about it here). Over time, we expect to provide more granular scoring to take into account significant differences in boundary coverage.
- Choice is provided as to whether data will be collected or applied for the purpose of ad targeting. Currently, any choice mechanism suffices for a full score on this point, even though obviously in some cases the choice offered only affects ad selection and not data collection. This is another area for improvement to the scoring.
- Accountability is provided by industry or other independent organizations. Currently, we award points for regular compliance reviews of internal processes by industry organizations (such as the Network Advertising Initiative), as well as ongoing external monitoring of practices by industry organizations (such as the Digital Advertising Alliance). Soon we will also include other independent privacy audits and compliance efforts.
If you have trackers on your site that don’t meet these criteria, we suggest that you reach out to them to find out why. If you’re not satisfied, remove their tags from your site. If they are being brought to the party from an ad exchange or optimizer, ask the intermediary what privacy qualifications they are requiring of their participants. (Feel free to send them our way, too, particularly if they believe we’ve scored them incorrectly.)