Privacy Notices - It’s Back To Basics (Without The Boilerplate)

Earlier this year, I reported that the Office of the Privacy Commissioner of Canada (OPC) was participating in the first ever Internet sweep by the Global Privacy Enforcement Network (GPEN).

The results are in. If you haven't dusted off your privacy policy for a thorough clean-up, you should.

Yesterday, the OPC reported that globally the GPEN found that almost a quarter of the 2,276 mobile Apps and websites examined did not have a privacy policy available. One third of the privacy policies that could be found raised concerns regarding the relevance of the information. In particular policies:

• used boilerplate language with brief over-generalized statements
• failed to provide information customized to describe the organization's practices