Benchmarks for Global Privacy Standards (November 2009)

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4.2. Benchmark 2 – Usability

Privacy rights should be easy to understand and use for consumers, and easy to manage for business and regulators.

A Global Privacy Standard should promote privacy protection that meets the following criteria:

1. Privacy protection should be easy to understand for consumers. In particular, the use of short form and summary privacy policies should be encouraged and promoted.

2. Privacy protection should be accessible. There should be a focus in privacy documentation on the use of plain language, and measures to ensure that information is accessible for people with relevant disabilities. Information should be provided in multiple languages where appropriate.

3. Privacy protection should not be overly complex or expensive to manage and implement. In particular, complex, costly registration processes that use up scarce funds and resources should be avoided, as they have delivered only minimal benefits to consumers at great cost.[9]

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[9] Jurisdictions that have implemented privacy legislation more recently have tended to exclude costly registration processes. See Connolly C, Asia-Pacific Region at the Privacy Crossroads, (2008) World Data Protection Report 9(8), pages 8-16. Also, see the discussion in China on the potential exclusion of registration requirements in their draft privacy legislation in Sutton G, Xinbao Z, Hart T, Personal Data Protection in Europe and China: What lessons to be Learned?, EU-China Information Society Project, November 2007.

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