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PrivacyBot FAQ
- What is PrivacyBot?
- What are the Benefits of Using PrivacyBot?
- What is the PrivacyBot Trustmark Registry?
- Are There Any Conditions for Joining the PrivacyBot Registry?
- How Does PrivacyBot Influence a Site's Actual Practices?
- How Do I Join PrivacyBot and Get the Trustmark?
- Am I Required to Join the Trustmark Registry?
- What if I Revise My Policy or Change My Privacy Practices?
- What is the PrivacyBot Complaint Mediation Service?
- How do I File a Privacy Complaint Against a Trustmark Site?
- How Do I Manage and/or Terminate Complaints?
- How Do I Terminate or Cancel My PrivacyBot Registration?
- What is the P3P Spec and How Does PrivacyBot Comply?
PrivacyBot is a privacy seal program for web sites created by Invisible Hand Software (legal automation specialists since 1991). PrivacyBot makes it much easier and affordable to create a Privacy Policy and join a seal program. Our online Account Manager also lets you access and control your own account (24x7). Why spend weeks filling out unnecessary paperwork and coping with registration hassles?
You can get started today with a Privacy Policy and register to display our Trustmark on a "provisional" basis. Once you get set up and submit the Compliance Checklist, we will visit your site and get you converted to full "Active" status. Here are the main features:
PrivacyBot Mediation Service: U.S. privacy laws require privacy seal programs to offer a system of consumer redress and reporting. We devised an online mediation service to help web sites quickly resolve privacy complaints without getting lawyers into the act. For a nominal fee, consumers can file an online complaint form with PrivacyBot. We structure the grievance into a Notice of Mediation and Complaint. We then orchestrate an online mediation process to help the parties resolve it within fixed deadlines. Mediation is voluntary and non-binding. Unfavorable outcomes are noted publicly in summary form on the site's Registry Statement shown to users clicking the Trustmark for that site (details are not revealed).
What are the Benefits of Using PrivacyBot?
Attention Children's Sites: If you operate a commercial site with features directed to children under 13 or if you knowingly collect personal information from such children, you are now required to meet minimum privacy standards. PrivacyBot generates Privacy Policies that contain child-oriented provisions and supplies a Compliance Kit to help you administer these requirements. Be sure your actual practices are in line with our Eligibility Standards before posting the Policy or our Trustmark. Child-oriented sites should review the children's provisions in the Privacy Policy and our Eligibility Standards to make sure they understand the requirements.
What is the PrivacyBot Trustmark Registry?
PrivacyBot maintains a registry of sites authorized to display the Trustmark (sites are automatically pre-registered for one year when they create a Privacy Policy). Sites are registered on a provisional basis until you submit the online Compliance Checklist that will be emailed to you when you first join. Your web site displays the Trustmark on its main page. When visitors click the Trustmark, the PrivacyBot server displays a Registry Statement showing:
Are There any Conditions for Joining the PrivacyBot Registry?
Web sites joining the PrivacyBot Registry agree to our Eligibility Standards and our Terms of Service. Sites must post a Privacy Policy meeting our standards and must adjust their practices as needed to comply with the Policy before posting the Policy or the PrivacyBot Trustmark. New sites are admitted on a "provisional" basis until a Compliance Checklist is submitted. Sites should be willing to make a good faith voluntary effort to resolve user privacy complaints according our the Mediation Rules. It must also be willing to have its actual privacy practices assessed through our automated and manual mechanisms.
How Does PrivacyBot Influence a Site's Actual Practices?
First, we provide the tools and information needed for web sites to be good privacy citizens. We make it easy to create Privacy Policies addressing fair information practices. Sites that can see their responsibilities articulated in a written Policy can more readily adjust their practices as needed to comply with that Policy. Sites joining PrivacyBot agree to comply with their own Policy before posting the Policy or our Trustmark and during their period of membership. They must submit Compliance Checklists to maintain "Active" membership status.
We provide consumers an online system of consumer redress. Consumers may file an online complaint in the PrivacyBot Mediation Service. PrivacyBot structures the grievance into a proper complaint and forwards the papers directly to the Site's official contact. It then orchestrates a mediation process using program incentives to usher the parties toward a private resolution within fixed deadlines.
We reinforce that system with online real-time mandatory reporting of a site's privacy history with us. The initial filing of a complaint is noted on the Site's public registry statement. Unfavorable mediation outcomes are also noted in due course. We report a complete history of all privacy complaints filed against the Site, broken down by the nature of the complaints. Any user clicking the Site's Trustmark can see an up-to-date privacy history for that Site. Compliance reports also provide an early warning radar system to help identify problem Sites.
Any Site showing a pattern or practice of unresolved disputes, or even a single dispute of a particularly serious nature, are identified for closer scrutiny on an as-needed, targeted basis. We will require additional assurances from a problem Site. For example, we may require it to submit an interim Compliance Checklist or undergo a manual audit as a condition of membership.Noncompliant Sites will be suspended from our system. Some sites may be referred to the FTC for further inquiry.
How Do I Join PrivacyBot and Get the Trustmark?
Joining PrivacyBot is simple. Start by clicking "Join PrivacyBot" and fill out our online application. PrivacyBot will promptly set up your account, issue you the Privacy Policy and the Trustmark with simple installation instructions. At this stage, you are admitted as a "provisional" member (this status is displayed on the Registry Page presented to anyone clicking the Trustmark on your site).
To obtain full "Active" membership, you must submit an online Compliance Checklist, which you will receive by email a couple days later. The Checklist helps make sure you understand and are actually complying with the Eligibility Standards. Just submit the online Checklist whenever you achieve compliance and think you're ready for "Active" status. Our staff will conduct a site visit to help verify your compliance.
New members receive a Compliance Kit by email containing the Privacy Policy, the Trustmark configured for their site and simple installation instructions. The $100 annual fee includes the Compliance Kit and membership in the Trustmark Registry. Your PrivacyBot account will already be set up for you when you first obtain "provisional" status (at main menu, access-- Account Manager-- to manage your relationship with PrivacyBot).
Am I Required to Join the Trustmark Registry?
No. The PrivacyBot Trustmark Registry is voluntary. You are not required to display the Trustmark. Since you'll be pre-registered at the time you purchase a Privacy Policy, it's best to cancel your registration if you do not wish to participate. This only takes a minute. Just access the Account Manager at PrivacyBot's main menu (enter your email address and password). Then click "Manage My Registered Web Sites." At that screen, cancel your PrivacyBot registration. Be sure not to display the PrivacyBot Trustmark on your site.
What if I Revise the Privacy Policy or Change My Privacy Practices?
You can revise a Privacy Policy created at PrivacyBot. Minor changes are okay. If you make material changes to it, or intend to post a custom-drafted policy, be sure it complies with our Eligibility Standards.
If you later change your privacy practices, you can create a new replacement Policy for the same registered site for only $5 (access- "Account Manager" and click "Manage My Registered Sites").
Note: Sites with features targeted to children under 13 are generally required to obtain parental consent before collecting, using or disclosing information about children. If the site materially changes its practices, it must repeat the consent process for those new practices.
What is the PrivacyBot Complaint Mediation Service?
PrivacyBot helps consumers resolve privacy disputes against Trustmark sites without going to court. The Mediation Service should not be used to resolve other types of disputes, or privacy disputes with sites not belonging to the PrivacyBot Registry. Consumers are not required to use PrivacyBot mediation, and may instead file grievances with the FTC.
Users can file an online complaint against a Site displaying the PrivacyBot Trustmark (click the site's Trustmark, then "File a Complaint Against this Site"). PrivacyBot will display the Complaint Form with certain information about the Site pre-filled. PrivacyBot structures the grievance into a "Notice of Mediation and Complaint," forwards it to the Site's official contact. PrivacyBot then orchestrates a voluntary mediation process according to the Mediation Rules.
PrivacyBot Trustmark sites have agreed in good faith to try to resolve Complaints according to our procedures within fixed deadlines. Mediation is voluntary and nonbinding. Unfavorable outcomes are noted on the Site's public Registry Statement displayed to visitors clicking the Trustmark.
As a neutral third party, PrivacyBot does not take sides or decide the outcome of mediations. Instead, PrivacyBot uses structured procedures and program incentives to get the grievance elevated attention by the Site's designated PrivacyBot contact. It then helps usher the parties toward a sensible resolution quickly, at nominal cost.
There is a $1.50 user fee to file a Complaint. This nominal fee helps ensure the user is suitably mature (having a credit card is some evidence of that) and prevents this system from being used to lodge multiple frivolous complaints. This helps ensure legitimate Complaints get proper attention.
How Do I File a Privacy Complaint Against a Trustmark Site?
Before filing a Complaint, try to resolve the matter informally by contacting the Site's privacy manager. Click the Site's Trustmark. The Site's privacy manager is identified on the Registry Statement (click the person's email address to initiate an email message). PrivacyBot mediation is not required and you may instead choose to file a grievance with the FTC.
If you want to file a privacy-related Complaint and have it mediated by PrivacyBot:
As noted above, there is a $1.50 user fee to file a Complaint. This helps ensure the user is suitably mature (having a credit card is some evidence of that) and prevents the system from being used to lodge multiple frivolous complaints. This helps ensure legitimate Complaints get proper attention.
How Do I Manage and/or Terminate Complaints?
Web sites and consumers who filed Complaints have accounts already set up for them on PrivacyBot. Just access "Account Manager" at the main menu. Click "Manage Privacy Complaints that Involve Me."
Either party can "Send a Message to the Other Party" or "Dismiss This Complaint" to terminate mediation. If the web site dismisses the Complaint or fails to resolve it during the Mediation Period, the public Registry Statement will reflect the unfavorable outcome in summary form. The Trustmark provides one-click access to the site's mediation history.
How Do I Terminate or Cancel My PrivacyBot Registration?
Web sites belonging to the PrivacyBot Registry may cancel their membership at any time. Just access "Account Manager" at the main menu. Click "Manage My Registered Sites". Locate the name of the web site and click "Cancel My PrivacyBot Registration for this Site". If you cancel your registration, you should immediately remove the Trustmark from your site. Note: annual membership fees are not refundable upon cancellation of a site.
What is the P3P Specification and How Does PrivacyBot Comply?
The Platform for Privacy Preferences (P3P) is an international working group that has devised a technical specification for expressing Privacy Policies in a machine-readable standard XML format. These Policies can be retrieved automatically and interpreted by P3P compliant web browsers, electronic wallets and the like. PrivacyBot complies with the version of the P3P Candidate Recommendation, issued December 2000.
The idea behind P3P is to enable the development of server-side technologies, like PrivacyBot, and corresponding client-side technologies (e.g., next-generation browsers, browser plug-ins and other user agents) that will seamlessly identify and negotiate privacy preferences in a semi-automated manner. Such user agents are expected to arrive within the next year, so it is important for web sites to prepare now by posting a machine-readable version of their Privacy Policy (along with the human-readable version, of course).
The PrivacyBot Drafting System automatically produces a machine-readable version of your Privacy Policy in XML format. It is appended to the end of the human-readable version and available via the Account Manager page. Simple instructions for posting the XML (compact and full) versions on your site are also included in the Account Manager. Note: if you modify your human-readable Privacy Policy, be sure to have a qualified technician make corresponding changes to the P3P policy content.
