All TRUSTe® licensees must pass a rigorous process to meet our program requirements and agree to monitoring and dispute resolution. TRUSTe's compliance department conducts at least two automated scans of each licensee Web site each year to check for compliance with program requirements. We also monitor email procedures and email lists for all Web sites through seeding. Finally, we rely on consumer reporting of privacy violations to help uncover any breaches of privacy promises. We provide a number of services that both protect consumers and help companies stay compliant.
TRUSTe Certification, Watchdog, and Termination Diagrams
Certification
Quality Assurance
Email Seeding
MAXAMINE Monitoring
Watchdog Dispute Resolution
Trademark Enforcement
Appeals from Terminations for Convenience by TRUSTe
TRUSTe Certification
Not everyone can join the TRUSTe program. Applicants to the TRUSTe program must complete a rigorous, nine page self-assessment which goes into a detailed account of information collection, use and procedures. TRUSTe account managers review all self-assessments against actual Web site procedures and disclosures with a site walkthrough. Then, applicants are given instructions and disclosures to ensure their privacy statement is accurate and meets our license agreement standards. About 12% of applicants fail to complete the certification process.
Quality Assurance
Prior to certification a subset of Web sites are chosen for a second round of quality assurance checks to ensure consistency in the certification process. In addition, sites which are certified to higher standards defined by regulatory statutes (such as COPPA or EU Safe Harbor) are all reviewed to ensure compliance.
Email Seeding
During the certification process the account managers utilize a customized email seeding application to test the subscribe, unsubscribe and other email account-related features of a licensee's Web site and practices. The TRUSTe compliance department monitors the email activity of our licensees who collect email addresses via their Web site by securely creating anonymous email accounts. These email accounts are used to seed email lists of our licensees.
MAXAMINE Monitoring
TRUSTe uses a combination of MAXAMINE Knowledge Platform (MKP) technology and personal attention to scan licensed sites for breaches of their privacy policies. TRUSTe employs a subset of the MKP capabilities to automatically scan all licensees at least twice per year. During these scans, compliance analysts look for things such as encryption measures on sensitive pages and undisclosed "cookies" or single-pixel tracking devices. Usually, violations are unintentionally introduced when organizations update their pages, undergo changes in ownership, or launch new initiatives such as contests or newsletters. Whether these infringements are accidental or deliberate, compliance analysts inform the licensee immediately and help them to correct the mistakes before consumer confidence can be injured.
Watchdog Dispute Resolution
The online Watchdog program allows TRUSTe compliance analysts to mediate privacy-related disputes between consumers and licensee organizations. Should consumers perceive a privacy-related concern, they are encouraged to contact the licensee directly first. In the event that the licensee is unable to resolve conflicts with consumers, they can register the complaint online. If this happens, one of our compliance analysts will contact the licensee directly with the complaint and provide the individual with detailed instructions of their next steps. Barring ineligible complaints, TRUSTe has resolved 100 percent of consumers' complaints received through the Watchdog program. For a more detailed overview, please see the Watchdog process.
Trademark Enforcement
To ensure recognition for the effort invested by our licensees to meet our standards and by TRUSTe to ensure ongoing compliance we vigorously enforce the TRUSTe trademarks. The value of the trustemarks lies in consumer trust. To ensure that substandard organizations are not pirating the TRUSTe seals, compliance analysts keep a close watch on all displays of logos and seals for proper implementation and – in the case of deactivated licensees – prompt removal of the seals. We rely on vigilant individuals to report suspicious use, and we independently proactively review sites linking to the TRUSTe Web site.
Appeals from Terminations for Convenience by TRUSTe
Sections VII.C. and VII.E of TRUSTe License Agreement 9.0 provide that, in the unlikely event that TRUSTe terminates a Licensee for convenience, the Licensee may appeal that decision to TRUSTe’s Board of Directors (“TRUSTe Board”). The appeals process is as follows:
Process Appealing a TRUSTe decision to Terminate a Licensee for Convenience
- TRUSTe will send Licensee a Notice of Termination for Convenience 20 business days prior to termination.
- Licensee has 5 business days from receipt to invoke review by the TRUSTe Board by submitting a written statement to TRUSTe explaining why the termination should not go forward and requesting an appeal.
- TRUSTe will transmit Licensee’s appeal to the TRUSTe Board within 5 business days of receipt of such statement.
- The TRUSTe Board will review Licensee’s request and will endeavor to reach a decision within 15 business days.
- The TRUSTe Board will transmit its decision to the Licensee and to TRUSTe within 30 calendar days.
- Termination shall become effective upon completion of Board Review unless more than twenty-five percent (25%) of the members of the Board then in office object to the termination.
To learn about the process applicable to Appeals from TRUSTe’s decision to terminate a Licensee in other circumstances, read the description of the TRUSTe Watchdog Dispute Resolution process at
http://www.truste.org/consumers/compliance.php.
