- 2. When Do You Need to Send an Update Notice?
- 3. Why Send an Update Notice to Your Customers?
- 4. Your Customers Expect You to Share Your Data Practices
- 5. How to Send an Update Notice
- 5.2. Send an Update Notice Email
- 5.3. Use a Pop-Up Notice on Your Website
- 6. Summary
Remember that in addition to making those changes, you also need a record of the changes you made. So, keep each outdated version of your policy filed away for safekeeping.
When Do You Need to Send an Update Notice?
The answer is no. If you update the language or structure of your policy, then you don't need to send an update notice.
Why Send an Update Notice to Your Customers?
You need to let them know you changed your policy, so that they can provide their consent (or decline to do so) on your up-to-date practices.
You need to be particularly careful if your site markets to children because not only are there more laws (COPPA), but they can be stricter about privacy violations.
Your Customers Expect You to Share Your Data Practices
Users expect you to be transparent about your data practices and there's a growing privacy consciousness across the consumer market.
The Facebook-Cambridge Analytica scandal contributed to heightened privacy concerns among millions of Americans. A Harris Poll survey found that 78 percent of consumers believe that protecting user data is "extremely important." Trust in companies is also down. Only 20 percent of consumers say they "completely trust" businesses to protect them.
To put this into perspective, Harris Poll asked participants to weigh their concerns. Sixty percent of consumers reported greater worries about cybersecurity than about the potential of the U.S. going to war.
Consumers' fears and beliefs dictate who they will and won't get their data - and their money. So, it's important to be as transparent as possible.
Conduct a privacy law self-audit to make sure you have the most accurate assessment of your situation so you can present it transparently to your users.
How to Send an Update Notice
You don't need to take out a page-length ad in the Times to let customers know your data practices have changed. In fact, there are three simple notification methods that cover your bases and maximize transparency.
- Sending an email out to announce the changes
- Using a pop-up notice on your website to announce the update and obtain consent to the changes
Let's take a look at each method's benefits and how it plays out.
Hilton's "Changes to this Statement" clause reserves the right to modify the statement. Readers are informed that when material changes are made, a link will be posted on the site's homepage, and the effective date will be updated to reflect the current version of the policy:
The included change log includes a date of the change and a simple statement about what was changed, such as adding new information, updates for new laws, clarifications and removing outdated information:
Send an Update Notice Email
- Details of the most important changes
- What to do if a user doesn't accept the changes
According to OpenTable, starting May 31st, 2019, it would provide more detail about data collection, greater transparency related to what it shares, and mechanisms for more user control over their information.
Because the changes here are largely related to being more transparent and offering users more control - and not collecting or sharing new types of data - it was not necessary for OpenTable to provide a means by which customers can deny their consent.
The email also included a convenient list of all the changes. This is really helpful since without that, a user would certainly never really be able to tell what changes had been made.
If you send out an email, adding a summarized list like this is a really great idea and can be so helpful for your users. They'll certainly appreciate it and will be far less likely to want to opt out of your new privacy practices when they can easily learn what exactly the new practices involve.
Use a Pop-Up Notice on Your Website
Here's an example of a basic pop-up notice from Twitter:
Here's an example of a similar but somewhat better one from Zynga. It includes a link to the updated policies for users to easily access if they wish: