Federal Trade Commission
Dear Gramm-Leach-Bliley Agencies,
At Privacy Council, privacy is our business. Since our formation in early 1998, we have focused exclusively on creating solutions that businesses need to increase and maintain customer trust and long-term loyalty. We create these solutions from four divisions within our company. First, we create knowledge products, which keep individuals up-to-date on changing privacy legislation and regulations. Second, we provide technology tools, which assist businesses in writing privacy policies. Third, we provide a managed services division, basically an outsourced privacy staff for companies who desire an affordable, reliable privacy program. Finally, Privacy Council provides advisory services to businesses in need.
Internet Explorer 6 is going to change the Internet privacy paradigm forever with its P3P technology. P3P on IE6 helps a consumer evaluate the privacy risks of sites using 3rd party cookies and content. Sites that fail to create compact policies or evaluate their consistency with English language privacy policies, in light of IE6, face a multitude of issues from loss of visitors to possible litigation. The new P3P standards have the potential to help build consumer trust, but only if businesses accurately create and maintain their privacy policies.
Privacy Council has implemented its P3P Compliance Program in order to help businesses stay P3P compliant and maintain customer trust. The following discussion of our Program directly addresses the agencies concerns listed in Question 2 of the Federal Register Notice of the workshop because it explains how our Program helps create privacy notices that; 1) are easy to understand, 2) are effective, and 3) can serve as models for communication between businesses and customers.
Finally, Privacy Manager generates the TrustPage, which directly addresses the GLB agencies’ concerns of creating policies that are easy to find, easy to read, and easy to use.
In closing, we reiterate that Privacy Council exists to provide businesses with privacy solutions that increase customer trust. We believe that effective financial privacy notification is essential to achieving the full potential of ecommerce. Our P3P Compliance Program gives businesses a comprehensive way to achieve privacy compliance and our TrustPage will help build customer confidence in privacy policies.
Dr. Larry Ponemon
Last Updated: Wednesday, January 30, 2002