Strategies for Drafting Privacy Policies Kids Can Understand
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University of Western Ontario
The goal of this research was to identify guidelines for the drafting of privacy policies that children and teens can interpret accurately and with relative ease. Achieving this goal required a three-pronged strategy. Firstly, the authors analyzed relevant literature on readability and document comprehension within the target age groups. Secondly, focus groups were conducted with children and teens to examine their experiences and practices of looking at and interpreting privacy policies on favourite kids’ sites. Based on this, a set of potential guidelines for privacy policies was identified, which was empirically tested in the third phase of the research. The end result is a set of guidelines for the drafting of privacy policies that the authors claim “make a difference, by actively improving the comprehensibility of privacy policies encountered by Canadian children and teens as they surf the net”.
Previous research by these and other authors indicates that privacy policies are “hard to find, long and often written at a reading level that is not accessible to most adults”. Prior research by the authors found that 49 of the top 50 kids’ sites do contain privacy policies. Those policies, however, are typically difficult to find. Furthermore, they tend to be long (1902 words on average), with average reading level scores of grade 11 to grade 12. (Grade 8 is the recommended level for documents directed at adults, according to the Flesch grade level test.)
Although readability formulae are typically used to assess the comprehensibility of privacy policies, the authors warn that writing policies to readability formulae does not, in itself, guarantee comprehension. The bulk of the report focuses on a set of proposed guidelines that address the language of privacy policies, the structure of the text and the overall design of policies. There are 14 specific guidelines under these three categories: for example, one guideline suggests that double negative construction should be avoided. These guidelines are identified based both on reader feedback and on previous research on the factors that influence reading comprehension. The extended description for each guideline cites relevant research findings, identified comments from young people that are relevant to the guideline, and provides practical examples of positive and negative instances of the guideline. To test the effectiveness of the guidelines, the authors compared original and revised versions of actual online policies (with disguised names). Thirty-five participants aged 11 to 17 participated in the testing. Comprehension was improved with the revised policies, and participants were more able to accurately report the information collected by the site. In addition, participants overwhelmingly preferred the rewritten versions. The report includes a useful table summarizing the guidelines.
The authors also found that kids care about privacy. In the focus groups conducted by the authors, it became clear that, while privacy is not a primary goal of online activity (in this respect, the authors consider children to be no different that adults), it was clear that children and teens feel uncomfortable with the pervasiveness of online surveillance, but feel disempowered to do anything about it. As one girl put it, there are doors on the Internet, but “the doors are broken”.
The authors also found that a general distrust of organizations that collect personal information on the Internet permeates the expectations of the privacy policies that children and teens encounter online. They expect these policies to make it more difficult to discover what happens to their information and they attribute bad will to the drafters. As one 17 year old boy said, they “take advantage of the kids? cause they can’t read at university level”.
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OPC Funded Project
This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.
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