Tip: Determine whether changes to your Web site are “material changes” requiring you to notify all site users and TRUSTe.

If your company makes changes to the way you collect, use, or disclose your customers' personally identifiable information, give them notice so they can choose whether they want to continue sharing their information with you.

In order to keep your TRUSTe seal, you must also notify your TRUSTe account manager of material changes to make sure they do not violate the terms of your agreement with us. Examples of material changes you may not have thought of:

• Adding new collection fields, such as a refer-a-friend feature, that did not exist before
• Using pre-existing customer data for a new use, such as adding a consumer to a new email list
• A business transfer or acquisition

Once TRUSTe gives its approval of the material changes, your account manager will help you disclose the new practices in your privacy policy, secure TRUSTe approval of the revised policy, and properly notify customers of the changes.

Customer notification can range from placing a prominent notice on your Web site for 30 days to sending an administrative email to your customer base 14 days prior to implementation of the changes. The level of notice TRUSTe requires depends on the impact of the material change proposed.

Heidi Berger is an account manager at TRUSTe.

Read past tips at www.truste.org/sealholders/tech_tips.php.

 

Wiley Rein LLP