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ARTICLE · 01 SEPTEMBER 2016

Ten Common Problems That Plague Privacy Policies

​In my software consulting years, it was remarkably routine for clients to concede that they had never read their own procedures and documents.

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​In my software consulting years, it was remarkably routine for clients to concede that they had never read their own procedures and documents.  While it lent itself to amusing anecdotes like the database administrator who kept his notes in Klingon, the phenomenon reflects a practical problem: employees cannot fulfill obligations they do not know about. Ignorance makes compliance impossible.

In the Privacy Policy context, what you don't know can certainly hurt you. An aged Privacy Policy is like expired cheese: it can never help you, but it definitely has the potential to injure you.

Yet many mistakes are easy fixes. Here are the top ten we deal with most often.

10. Wrong State. Different states impose different requirements. For instance, Connecticut requires specific provisions pertaining to Social Security Numbers. All too often however, policies do not address the nuances of applicable state laws. The company needs to be familiar with the applicable

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