Tag Archives: policies and procedures

Online Privacy, Do Not Track, and the “Post-Cookie” World: New Guidance from the IAB

115562673_03b7fceea6_nEven as website owners and operators struggle with how to comply with recent changes to the law governing Online Privacy Policies, changes to the underlying technology are in the works, bringing about the so-called “Post-Cookie World” and begging the question of how to adapt your online privacy policy to meet this new technology. I won’t pretend to understand the intricacies of cookie or post-cookie technology; my concern is drafting online privacy policies for my clients that adequately address whatever technology is currently in vogue and understanding just enough of it to do so.

In an effort to understand the underlying technology just enough to be dangerous (and glean some drafting principles that may follow from it), I recently came across guiding principles for developing cookie replacement technology published by the Interactive Advertising Bureau (“IAB”) entitled “Privacy and Tracking in a Post-Cookie World.” In developing its guiding principles, the IAB begins by “Imagining a world where HTTP cookies were never invented” and suggests that, in developing alternatives to the cookie for tracking consumers, it is important to bear in mind what the consumer wants.  In my experience dealing with regulators who have no concept of something being outside their regulatory authority (particularly with consumers complaining to them), the IAB is correct that a proactive approach could keep the regulatory wolves at bay: Continue reading Online Privacy, Do Not Track, and the “Post-Cookie” World: New Guidance from the IAB

Record Retention Policy: Why It is in Your Company’s Best Interest to Have One

Bunch of Papers by Seiichi Kusunoki - Visual Maintenance*
Bunch of Papers by Seiichi Kusunoki – Visual Maintenance*

There are good legal and practical reasons for your company not to hold onto every document that comes across its proverbial desk. There are also good reasons not to destroy documents too hastily. Instead,  you can adopt a well-considered record retention policy that dictates which documents are retained, for how long, and when to destroy them. Working with your legal counsel to draft the policy will help ensure the proper timeline for document destruction and help you avoid legal headaches.

First Things First – What is a Record?

Records include essentially all documents created or kept by the business in paper (or other tangible format) or electronic form. This includes paper-based documents, e-mails, electronic files and programs, desk calendars and appointment books, photographs, plans, maps, diagrams, and various other vehicles for the transmission of language, images, plans, and numbers.             Continue reading Record Retention Policy: Why It is in Your Company’s Best Interest to Have One