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Center for Plain LanguagePrivacy-Policy Analysis

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BRIEF

INTRODCTION

Personally identifiable information—or PII—refers generally to informationused to identify a unique person. Definitions vary, and the law varies withrespect to organizations’ responsibility to protect PII. rganizations withaccess to PII typically publish privacy policies, so potential consumersshould be able to understand their privacy rights and evaluate the ris!s they would ta!e if they associate with the organization. " privacy policy that consumers are unli!ely to read or understand providesno protection whatsoever. #hen $I%&.com began evaluating a variety of Internet'based companies’ privacy policies, they sought help from the (enter for Plain )anguage. $he (enter is a *+-c-/, non'profit organization that helps government agencies and businesses write clearly.

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$he (enter1

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2upports plain'writing legislation.

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3rades government writing through its 4ederal 5eport (ard.

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(elebrates good writing through its (lear%ar! "wards.

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Publicizes bad writing through its #onder%ar! "wards.

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(onnects companies and plain'language consultants.

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6logs about plain language.In response to $I%&.com’s request, the (enter evaluated seven companies’ policies to determinehow well they follow plain'language guidelines. 7" communication is in plain language if its wording, structure, and design are so clear that the intended readers can easily find what they need, understand what they find, and use that information.8$he results of our study are quite consistent, especially at the top and bottom of the ran!ings1 3oogle and 4aceboo! do a good 9ob of communicating their privacy policies in a way that allows consumers to understand and ma!e decisions—at least motivated consumers. "nd )yft and $witter do a poor 9ob of communicating those policies. $he remaining companies—)in!edIn, :ber, and "pple—do better in some areas than others.

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$his pro9ect was led by ;ulie (lement of ;. (lement (ommunications. ;ulie retired after < years as a legal'writing professor. 2he now trains, coaches, and consults with law firms, government, and businesses in the areas of plain language and legal writing. 2he serves on the (enter for Plain )anguage’s board of directors and is the editor in chief of

The Clarity Journal

, the 9ournal of the international organization for plain legal language.

2 http://centerforplainlanguage.org/1

Our ranking of the privacy policies:#1Google#2Facebook#3inke!"n#$pple#%&ber#'T(itter#)yft

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#e used e=pert 9udges and "crolin=—a 7content'optimization platform8 to evaluate online privacy policies for the following1

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$wo Internet ecosystems1 "pple and 3oogle

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$wo Internet'based ride'sharing services1 )yft and :ber

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$hree social'media services1 4aceboo!, )in!edIn, and $witter #e evaluated the policies at three levels1

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rganization, navigation, signposting, and information design

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2entence level topics, such as sentence structure, word choice, and tone

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$he 7spirit8 of the law $he first category or level loo!s at what specialists consider the !ey components of comprehension—the higher order concerns that allow a reader to become oriented to the information, to locate information, and to truly create meaning. $he second category loo!s at what specialists consider the !ey components of decoding, or the lower order concerns, that allow a reader to translate the letters into words and words into sentences and sentences into understanding. "nd the third category allows us to loo! beyond the letterof the law

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which all companies will have met

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to 9udge whether they have done more to ensure that their policies are transparent. #e used "crolin=, the same program we use for the (enter’s 4ederal 5eport(ards,

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to create the sentence level scores. #e used a variation of the(enter’s (lear%ar!

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criteria to evaluate the other two categories.

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The judges

$hree plain'language e=perts 9udged the privacy policies for higher'order concerns, along with sentence'level concerns. &ach of the 9udges is a(enter for Plain )anguage board member.

De+ora, Bosley

, PhD, $he Plain )anguage 3roup. Deborah hasspent the past 0+ years wor!ing with 4ortune ++?*++ corporations, attorneys, governmentagencies, and non'profits to create written information that meets regulatory requirements

3 http://centerforplainlanguage.org/report-cards/4 http://centerforplainlanguage.org/clearmark/2

*e use! e+pert ,u!ges an! an online platfor- to evaluate three categories:

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.igher/or!er organi0ation  !esign co-ponents

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o(er/or!er co-ponents at the (or! an! sentence level

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*hether the co-panies respect the spirit of the la(

and is easy for people to understand and use. $P)3 offers research and testing, training, revision and redesign, and consulting.

*eg,an Co "al.er

, @uula (onsulting. %eghan is a writer and content e=pert who helps clients understand — and unleash — the power of clear communication. Aer client e=perience ranges from fashion designers to social 9ustice campaigns, but she specializes in supporting the financial services industry.

/eff %reer

, Digital (ontent 2trategist, 6lue (ross 6lue 2hield of %ichigan. In his role at 6lue (ross, ;eff is responsible for the content strategy and delivery of the company’s websites. Ae focuses on using plain language and simple interactions that help %ichigan ma!e sense of health insurance.

Judging criteria

$he 9udges used the seven categories below to assess the policies. 4or each category, 9udges were as!ed to consider a variety of questions, and to rate the policy as outstanding, aboveaverage, competent, spotty, or clueless in that category.

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nerstaning auience nees

"s the notices (riting4 tone4 an! presentation appropriate to the target rea!er5 "s it clear (hat the rea!er shoul! learn fro- this notice5 6oes the notice offer user/frien!ly capabilities5 For e+a-ple4 are key (or!s !efine! as rollovers or links5

#tructure 0 navigation

$re the notices sections clearly organi0e! an! labele!5 6oes the notice use a!vance organi0ers4 such as tables of contents4 si!ebars4 or overvie(s5 *ill labels 7if any8 help users pre!ict (hat is in each section5 "s the content presente! in a logical (ay5

Presentation 0 inforation esign

6oes the notice inclu!e typography4 color4 (hite space4 or si-ilar tools to gui!e the rea!ers attention5 6oes the layout an! presentation -ake the notice easy to scan5 Can you tell by glancing at the notice (here the i-portant infor-ation is5

Pictures( gra2,ics( 0 c,arts

6o the pictures4 graphics4 or charts correspon! to an! support the content in the notice5 *ill they help rea!ers un!erstan! i-portant points better or gui!e the- on their !ecision to interact (ith the co-pany5

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$he 9udges also evaluated the policies on writing, voice, and whether the policy honored the spirit of the law. $hese categories are addressed later in this report.

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