Saturday, March 21, 2009

Privacy policy for blogs and email?

As part of their new interest-based advertising program, Google is reminding us AdSense publishers to update our privacy policies, telling us that "Visitation information from publisher sites will be used to create user interest categories, delivering more relevant ads and improving monetization for publishers over time." Privacy policy? I have never had any formal, published privacy policy for any of my web sites, primarily since my sites are static and do not actively collect any data. But, technically, some data is gathered behind the scenes, primarily logging of page views. Also, I do have some pages with a Google search box to search my web sites and Google may or may not "collect" user usage data for those searches unbeknownst to me. I suppose I need a policy for any email that people might send me, but that is more of an email policy rather than a policy of the web site. I probably should have a policy for blog comments as well.

My overall personal policy is that I never do anything with any user data (including email), other than to respond directly to the user.

Out of curiosity, what is the "default" policy under controlling law if no policy is displayed? Is it maximal respect for user privacy (what I do) or is it maximal use of user data?

Simple question: If one has a blog on Google Blogger, where it is Google that is controlling most user data, what privacy policy is needed to cover user page views and comments, especially where we bloggers cannot even know exactly what Google may be doing behind the scenes? Given that it is superficially absolutely clear that user comments on blogs are visible and accessible to the world, what privacy does the user retain? Maybe reuse and copying, but there is probably some controlling law there as well.

Hmmm... what if the user types in their own copyright notice in their comment text? And then what if Google ignores it -- who is violating what then??

As far as email, if a user sends an unsolicited email to me, what privacy obligations do I have to obey or even disclose? My personal email policy is that any email is a private communication and requires explicit permission to be forwarded or published elsewhere.

I do have to admit that on occasion I will excerpt from an email message or comment anonymously, but I do so in a way that does not violate privacy.

All of this said, I suppose I should formalize a privacy policy, maybe roughly what I have written in this blog post and just put links to it on my blogs and home pages of my web sites.

Or, maybe there is a generic privacy policy analogous to my personal policy so that I do not need to personalize it.

Please comment on the privacy policies that you use or would prefer. And... be sure to explicitly state whether I have permission to "steal" your policy!

-- Jack Krupansky


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