Privacy White Lists - Don't be Fooled (2009)

2.5. USA – TRUSTe Children’s Privacy Seal

TRUSTe offers a Children’s Privacy Seal – a specific privacy seal with special children’s privacy requirements. It has approximately 41 members (although this includes multiple sites belonging to a single organisation such as Disney).[9]

TRUSTe (like Privo) is approved as a trustmark scheme for compliance with the Children's Online Privacy Protection Rule (COPPR), and they highlight this Government approval on their web site:

The Federal Trade Commission has approved TRUSTe as a COPPA Safe Harbor program. The TRUSTe Children’s Seal certifies that your business is compliant with the COPPA Rule – letting parents know that their kids’ information is safe.[10]

However, this Government approval does not mean that privacy protection is assured – TRUSTe has the same issues with broken and missing seals and expired members as other trustmark schemes.

The Galexia study made the following findings:



Non-Compliance %

No working seal

A working seal does not appear on the organisation’s web site


Membership has expired

The membership is not current


Privacy policy not available

The organisation’s privacy policy is not available


Overall non-compliance

Cumulative total



The TRUSTe white list does not publish expiry dates, so the Galexia study assumes all working seals are current.

The Galexia study also examined whether member sites still describe TRUSTe as non-profit, as this is an ongoing concern with TRUSTe.

On 15 July 2008 TRUSTe changed its status from non-profit to for-profit and accepted investment from Accel – part-owners and Directors of Facebook. Nearly a year after the change the majority of TRUSTe members still retain the standard (old) TRUSTe wording in their privacy policies:

XYZ is a licensee of the TRUSTe Web Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence...

The Galexia study found that 29 out of the 51 sites still claim that TRUSTe is non-profit. This misleading information should be corrected.

TRUSTe Strengths

  • The TRUSTe white list is available to the public;
  • A deep verification link is provided wherever the seal appears;
  • Privacy standards are published; and
  • All sites had published privacy policies.

TRUSTe Weaknesses

  • No expiry dates are published;
  • A high proportion of links were broken (although sites could still be located through searches); and
  • A large number of sites still incorrectly claim that TRUSTe is non-profit.

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