This guide details the considerations that go into scoring privacy vendors, providing a brief summary of key evaluation criteria.
Cookie Policy
Choice
- Does the website provide meaningful choices about cookie usage?
- Is essential information shared with users before they make cookie-related choices?
- Users should be informed on how to opt out of non-essential cookies and tracking.
Enforcement
- How does the organization ensure adherence to its cookie policy?
- How is this policy communicated to users?
- The cookie policy should be maintained for accuracy, reviewed regularly, and updated as needed.
Notice and Disclosure
- Does the organization adequately inform users about its use of cookies? How is this disclosed?
- The cookie policy should be clear, thorough, and easy to find.
- It should detail the cookies used, their purpose, and the type of consent required.
Follow-Up
- Are there any unusual or concerning aspects in the organization's privacy practices?
GDPR Statement
Accessibility
- How accessible is the organization’s GDPR statement for users seeking transparency about data processing?
- The GDPR statement should be easy to locate, understand, and comprehensive.
Choice
- Does the organization offer users choices regarding the collection and use of their data?
- Users should be informed about how they can exercise their rights under GDPR.
Enforcement
- What actions does the organization take to demonstrate GDPR compliance?
- How is accountability for GDPR adherence ensured?
- Entities responsible for GDPR enforcement should be clearly defined.
Notification
- How does the organization notify users about data processing activities?
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The GDPR statement should be easy to find and understand.
Identification
- How does the organization clarify its role in data processing for GDPR purposes?
- Users should be able to identify whether data is collected and understand the organization's role (processor or controller).
Notice
- How are users informed about data collection and usage practices?
- Details about high-risk data uses should be provided.
- The legal basis for data processing should be clarified.
- Users should be informed about data transfers to other entities or regions.
Subject Rights and Obligations
- How does the organization enable users to exercise their GDPR rights?
- Users should be informed on how to opt out of data collection.
- The process to correct, delete, transfer, or restrict data, or withdraw consent, should be clearly explained.
Privacy Policy
Accessibility
- Is the privacy policy easy for users to find and understand?
- The policy should be clearly accessible and straightforward.
Choice
- What choices are available to users regarding their personal information?
- Consent requirements for sharing information and revocation methods should be detailed.
- All uses of personal data should be listed.
Enforcement and Accountability
- How does the organization enforce its privacy policies and uphold best practices?
- Accountability mechanisms and applicable regulations should be explained.
- The policy should be kept accurate and updated.
- Information on how to raise questions or complaints should be provided.
Notice
- How does the organization notify users about its data privacy practices?
- The policy should disclose the types of data collected and how it's gathered.
- Clarify if data is sold or shared.
- Describe the consent process for data collection.
Rights and Obligations
- How does the organization inform users of their privacy rights and responsibilities?
- Clearly outline how users can exercise their rights (e.g., to correct, delete, or transfer data).
Security
- What security measures are in place to protect user data?
- Detail security measures and procedures in the privacy policy.
Security Statement
Administrative Security
- What administrative measures are used to safeguard data?
- Detail training programs, personnel screening, and security protocols.
Certification
- Does the organization hold any security certifications?
- List all third-party security certifications held.
Enforcement and Accountability
- How does the organization validate its security practices?
- Detail internal testing and external audits.
Operational Security
- What operational security measures are in place?
- Describe processes and controls ensuring operational security.
Physical Security
- How is physical security maintained to protect personal information?
- Detail facility security measures and protocols.
Product Security
- What security protocols are applied to the organization’s products or services?
- Describe specific security features integrated into products and services.