Authored by:
Monica Meiterman, Partner at Tueoris
With each state privacy regulation that emerges, there is growing scrutiny over organizations’ collection and processing of consumer personal information. More than ever, organizations are being held accountable for the personal information being collected directly from consumers in addition to the personal information third parties are being allowed collect or process from its properties.
One of the most prominent areas impacted by these changes is digital properties and the tracking technologies that are being placed and collecting consumers’ personal information. To comply with the US regulations, organizations need to invest significant and continuous time and resources in:
1. Identifying tracking technologies in use or planned;
2. Reviewing each individual tracking technology and properly verifying which tracking technologies may be considered a “sale” or “share”/“targeted advertising”; and,
3. Implementing the appropriate configurations or technologies to honor consumer choices, including manual and universal opt-outs.
Tueoris has developed the Sale/Share Opt-Out Decision Tree below (interactive version linked here) which addresses important considerations that help with the critical step of determining whether a tracking technology is subject to opt-out requests.
Since a single vendor can provide several tracking technologies with differing purposes, it is recommended that each tracking technology be reviewed individually, as opposed to at the vendor level. It is also important to note that certain considerations may not be applicable for organizations of all sizes or industries and each tracking technology should be assessed.
Tueoris has extensive experience in managing and implementing tracking technology management programs and platforms. For questions regarding this post or your organizations’ privacy program, please contact [email protected].
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