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Question 96 - CIPP-US discussion

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What is the most important action an organization can take to comply with the FTC position on retroactive changes to a privacy policy?

A.

Describing the policy changes on its website.

Answers
A.

Describing the policy changes on its website.

B.

Obtaining affirmative consent from its customers.

Answers
B.

Obtaining affirmative consent from its customers.

C.

Publicizing the policy changes through social media.

Answers
C.

Publicizing the policy changes through social media.

D.

Reassuring customers of the security of their information.

Answers
D.

Reassuring customers of the security of their information.

Suggested answer: B

Explanation:

The FTC has stated that it is a deceptive practice to make retroactive changes to a privacy policy that affect how a company uses or shares previously collected personal information, unless the company obtains affirmative consent from the affected consumers. This means that the company must clearly and conspicuously disclose the changes and obtain the consumers' express agreement to them. Simply describing the policy changes on the website, publicizing them through social media, or reassuring customers of the security of their information are not sufficient to comply with the FTC's position.Reference:

FTC Staff Revises Online Behavioral Advertising Principles, paragraph 3.

Do I really have to obtain consent from all my customers to make a change to my privacy policy?, paragraph 2.

IAPP CIPP/US Study Guide, page 64.

asked 22/11/2024
Alvaro Peralta
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