SB 27
requires companies that do business with California consumers and share
personal information with third parties, for marketing purposes, must
provide consumers with a designated contact point where they can request
an Information-Sharing Disclosure Notice. These notices must list the
categories of personal information that the organization shared, as well
as the names and addresses of the companies with whom the information
was shared over the preceding calendar year.
https://www.lynxtrack.com/signup.php
If your organization provides a means for consumers to opt in or opt
out of third-party sharing and if you disclose this in your privacy
policy, you can respond to the consumers' request for an
Information-Sharing Disclosure Notice with a Consumer Choice Notice
explaining the consumers' right to prevent further disclosure of their
personal information and a cost-free means of how to exercise that
right.
One way your organization can inform consumers of the designated
contact point for requesting an Information-Sharing Disclosures Notice
is through your Web site via a link on the site’s home page titled “Your
Privacy Rights” or “Your California Privacy Rights.” This link can take
the consumer to a separate page explaining their rights and providing
contact information for notice requests or it can take the consumer to
your site’s privacy policy, which should include a section regarding the
consumer’s privacy rights and the contact point for notice requests. It
is recommended that the California Privacy Rights section of the privacy
policy be placed toward the beginning of the policy or in some other
conspicuous location.
The California Office of Privacy Protection has recently published
some guidelines on Information-Sharing Disclosures and Privacy Policy
Statements on its Web site at
http://www.privacy.ca.gov/recommendations/recomend.htm. The
guidelines offer tips on best practices for providing
Information-Sharing Disclosure Notices and Consumer Choice Notices as
well as for crafting privacy policies.
Joanne B. Furtsch is a senior account manager at TRUSTe.
