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Re: [projectvrm] Fwd: [ PFIR ] Proposed California law requires site privacy polices not to exceed 8th grade language and 100 words


Chronological Thread 
  • From: Adrian Gropper < >
  • To: Mary Hodder < >
  • Cc: "Phil Wolff, PDEC" < >, Sean Bohan < >, J Clark < >, ProjectVRM list < >
  • Subject: Re: [projectvrm] Fwd: [ PFIR ] Proposed California law requires site privacy polices not to exceed 8th grade language and 100 words
  • Date: Tue, 12 Feb 2013 12:52:45 -0500
The white paper suggests 200 characters!, not words to describe the Purpose of the authorization. From there, the principle of access minimization could be used to simplify and justify the rest of the privacy policy - ideally in very few words.

Adrian

On Tue, Feb 12, 2013 at 12:25 PM, Mary Hodder < " target="_blank"> > wrote:
I don't think the proscribed reading level is the problem with the bill.. that would probably work out fine.

It's the length and the fact that it's customary to have multiple policies.. 2-4.. that would cause this bill to be toothless.

And I'm not sure you can tell people not to speak (or companies that == people).

What if just the list of collected data, in the slimmed down 100 word privacy policy, were more than 100 words?

Then what?  For facebook, this list is all possible

Ip Address
IP location
Name 
Address
City
State
Zip Code
Country
Birth date
Browser Type
OS Type
Pages visited within site
Pages clicked upon within site
"likes"
"comments"
Pages arrived from (offsite)
Pages going to (offsite)
Location checkins
contact's list
friend types
friends recommended to others
friend requests sent
friend requests received
Pages visited (offsite, with "like" or "comments"
Status updates
Shared from others
Payment information (for promoted posts and gifts)
Pages promoted
Gift and recipient
Ads clicked
photos uploaded
videos uploaded
links shared
searched within FB
searched outside FB
messages and IMs
promoted
job history
job years
quotes
liked items for profile
relationship status
schools attended
school years
history and year
privacy settings
login settings

I'm sure I've missed a bunch.. but that list is 116 words..

Even at 200 words, which Adrian's white paper on consent dialogs suggests, there's not a lot left for the rest of the dialog and privacy information.

mary




On Feb 12, 2013, at 4:14 AM, Phil Wolff, PDEC wrote:

A few examples come to mind in support of this attempt.

Readers' Digest targeted sixth-grade reading level for its entire history. They are famous for explaining law, foreign affairs, human biology, anatomy and physiology using simple language and illustrations. "This is Joe's liver"

Wikipedia has a "language" of "Simple English". This is a very restricted vocabulary (850 words) and writers are translating everything from engineering and Einstein's relativity to social sciences into Simple English. It really works, stripping away jargon, hundred-dollar-words where a five-penny word will do, losing all pretension. Intensely valuable for people for whom English is a second language, with some kinds of cognitive challenges, or for whom vocabulary is a barrier. http://simple.wikipedia.org/ http://simple.wikipedia.org/wiki/Special_relativity  

Apps that score text for readability often check word length (in syllables), sentence length, paragraph length, structure simplicity/complexity, and grammar rules that prevent semantic confusion. So overall length of a contract or advisory should help, but there are many other factors that contribute to readability and access by someone who doesn't read much or read well. 

I don't know if it's still true, but I was told when I first study technical writing that the average person is most comfortable reading three or four years below their highest academic grade level. Where inclusion is a goal, and I'd think it would be in the case of readable contracts, shooting for 6th grade seems both important and attainable. 



What's interesting about this is that it would be fairly easy to get around, if it passes.

So.. a site or app does a 100 word, easy to read Privacy Policy.

Then they do a TOU and Data Policy.. for the rest of what usually goes in those things.

It's silly to write a law this way.. and I think would also violate free speech rights...

I could see requiring a simple text summarizing a privacy policy in 100 words, but I just don't see this going anywhere useful, even if it does pass.

Which I doubt it will.


On Feb 10, 2013, at 11:51 AM, Sean Bohan wrote:

Awesome share - Thanks!

From a business context, Pharma companies and their agencies focus on a 7-8th grade reading level for all communications meant to be read/experienced by patients. 

On Sun, Feb 10, 2013 at 12:24 PM, J Clark < " target="_blank"> > wrote:
FYI, FWIW. 

In California, I was told a few years ago by a Criminal Prosecutor & Law School Professor, an average jury pool has an 8th grade education. Elsewhere in the US, it's closer to a 7th grade equivalent, which isn't saying much these days.



Begin forwarded message:

From: "PFIR \(People For Internet Responsibility\) Announcement List" < " target="_blank"> >
Date: February 9, 2013 7:33:50 PM PST
Subject: [ PFIR ] Proposed California law requires site privacy polices not to exceed 8th grade language and 100 words
Reply-To: "PFIR \(People For Internet Responsibility\) Announcement List" < " target="_blank"> >



Proposed California law requires site privacy polices not to exceed
8th grade language and 100 words.

We all do know that privacy policies can become long and complicated,
but they encompass complex principles.  And while we're probably very
much in favor of making them as understandable as possible, trying to
limit privacy policies in such an arbitrary manner makes about as much
sense as trying to legislate the value of pi.  In fact, the actual
bill itself would violate its own designated limits many times over.
And I've now just about hit the actual 100 word limit itself.  Sorry
about

http://j.mp/Z2CqEF  (Leginfo.ca.gov [PDF])

--Lauren--
Lauren Weinstein ( " target="_blank"> ): http://www.vortex.com/lauren
Co-Founder: People For Internet Responsibility: http://www.pfir.org/pfir-info
Founder:
- Network Neutrality Squad: http://www.nnsquad.org
- PRIVACY Forum: http://www.vortex.com/privacy-info
- Data Wisdom Explorers League: http://www.dwel.org
- Global Coalition for Transparent Internet Performance: http://www.gctip.org
Member: ACM Committee on Computers and Public Policy
Lauren's Blog: http://lauren.vortex.com
Google+: http://vortex.com/g+lauren / Twitter: http://vortex.com/t-lauren
Tel: +1 (818) 225-2800 / Skype: vortex.com
_______________________________________________
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--
------------------------------------------------
Sean W. Bohan






--
Adrian Gropper MD

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