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May
30

Designing Effective Policies

By Travis Pinnick
User Experience Designer | TRUSTe
@xtratrav

Policy policies as initially conceived were meant to afford consumers protection from poor data practices, but have since evolved to serve more as legal protection for the companies collecting the data. As such they are often needlessly complex and intentionally vague.

Therefore there is strong interest, especially among regulators and consumer advocates, to move beyond policies into easily digestible privacy short notices that can be represented in the browser.


Attempts to Summarize Policy Data

An early approach for simplifying the consumption of privacy policies was the Platform for Privacy Preferences (P3P) developed by Lorrie Cranor (Carnegie Mellon CyLab), which enables sites to express their privacy practices in a standard format that can be interpreted by machine-readable user agents. A short notice style of P3P agent which gained attention was the Privacy Nutrition Label by Patrick Gage Kelley (Carnegie Mellon CyLab), which was able to display P3P policies in a graphical matrix which compares the types of data collected to the uses of that data. A similar icon-based approach to visualizing privacy policies called KnowPrivacy was attempted by UC Berkeley graduate students Soltani, Gomez, & Pinnick. Both designs display policy data for a wide number of categories in a grid format.


(left: Kelley’s Nutrition Label; right: KnowPrivacy’s icon policy summary)


In 2010 Mozilla hosted a workshop about the use of privacy icons to communicate only the most important information practices to consumers. Workshop feedback suggested that privacy icons should ONLY be used when the user does NOT have a reasonable expectation regarding how data is used, and that the icons needed to represent a small number of categories in order to be useful in a consumer-based short notice.

The revised versions of the Mozilla icons (started by Aza Raskin and finalized by Alex Fowler and Ben Moskovitz with icon design by Disconnect.me) consisted of four categories: Third Party Use, Sharing with Ad Networks, Sharing with Law Enforcement, and Data Retention. Similar to other attempts at icon designs, each category (except for retention) used 2 icons per category to represent binary states.


What policy summaries mean to users

TRUSTe also conducted a user test of both the Mozilla policy summary icons and a similar set proposed by TRUSTe. Both were well received, but testing suggested the following conclusions:

  • Users don’t seem to have preconceived notions of what categories make the most sense regarding privacy. Every user tested was unable to articulate what categories they expected to see, but also every user agreed that the first categories they were shown met their expectations
  • Icons aren’t important, it’s presentation and finding the appropriate method (and timing) of delivery that’s important. The actual icon used seemed to be of minimal importance compared to user concerns over presentation of the short notice categories. No user was able to articulate clearly what icons they associated with the categories other than the ones shown, and several commented that icons work as long as they make reasonable sense in context

There is clearly a need for policy summary data, but consumers are looking to privacy and policy experts to find the appropriate method of delivery.


New applications for policy summaries

TRUSTe has also been encoding short notice data for client re-use.  We’ve built the capabilty to read this short notice data into our layered privacy policies, adding an extra summary layer to the full policy information.

We’ve also built the capabilty to read this short notice data into a couple of our products where it makes sense for a user to need this information (like at a decision making point regarding a site, app, etc). One example is our Tracker Protection browser client, a tracker blocker plug-in which can also read our policy summary data for a given site, the other is our EU Cookie Consent Manager offering.


Policy data and mobile

Mobile presents more challenges in delivering policy information. Most mobile apps and web apps have just as complicated data collection practices as their desktop counterparts, but with even less screen real estate available to convey this information.

Shown here is our mobile-optimized privacy policy we provide our mobile certification customers. TRUSTe and Privacy Choice also offer free mobile privacy policy generators for app developers.

Mobile also provides another opportunity for the delivery of policy summary data. Unlike normal web browsing, the nature of app usage provides an ideal time in the user experience to provide summary information – at the point of installation.

Shown here is an early version of our policy short notice integrated into our mobile-optimized privacy policy. Also shown is the treatment of android’s permission summary screen, which is an analogous example of delivering summary data at a highly relevant decision-making point in the mobile user experience.


(left: possible TRUSTe mobile short notice; right: Android permission consent)


Conclusion

An effective policy summary should:

  • Provide only the information that is most relevant, like the data collection practices which are invisible to users
  • Support a user’s ability to assess a site or app’s privacy practices at an appropriate time (like a decision making moment such as app download)
  • Support a method of delivery that is informative without being overwhelming or intrusive to the user experience

For all the talk about icons, what really matters is the delivery of easily consumable summary data at the appropriate time when it is most relevant and least intrusive.


For more on this topic see my talk at the PII 2012 creating effective policies panel with Casey Oppenheim (Disconnect.me) and Jim Brock (PrivacyChoice).

Follow me on twitter at @xtratrav.

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