Consumer data is collected, used, and shared responsibly and proportionately, only to the extent necessary for service delivery and compliance requirements (as opposed to generalized commercial purposes), and consumers retain meaningful and frictionless control over how their data is handled.
Data Minimization
- Users’ data exposure is limited to only what is necessary for service delivery and compliance, with no excess information collected.
- The entity that offers the product has clear, documented policies outlining its collection practices and makes those policies prominent and accessible to all users.
- The entity only collects the minimum amount and type of information necessary for service delivery and compliance requirements.
- Data is not collected solely for or justified through generalized commercial purposes, such as marketing or analytics, that are unnecessary for the delivery of the product.
- The product discloses all data collection, retention, use, and sharing practices with specificity and completeness.
- Data collection practices are aligned with product disclosures.
- The product does not limit functionality when the user restricts or opts out from data collection if the function can be provided without those data elements.
- User data is retained only as long as necessary and deleted in accordance with schedules that exceed basic legal requirements, without requiring users to configure or request these protections.
- The entity that offers the product has clear, documented retention and deletion schedules for different data types collected through the product and makes these policies prominent and accessible to all users.
- Data retention and deletion practices are aligned with product disclosures.
- The entity automatically deletes any user data it is not required to retain when a user deletes their account.
- User data is protected from broad internal use, with access limited to specific, clearly defined purposes that users can reasonably expect.
- The entity has clear, documented policies in place to limit the use of product data internally and makes these policies prominent and accessible to all users.
- Data use practices are aligned with product disclosures.
- The product does not limit functionality when the user restricts or opts out from specific uses of their data if the function can be provided without those data elements.
- The product asks for express, informed consent in plain language before using data for any purpose not initially disclosed to users.
- Third-party data sharing is strictly limited to what is necessary for service delivery without sacrificing the quality of the product and never used for unrelated commercial purposes without explicit informed consent.
- The entity that offers the product has clear, documented policies in place to limit the amount and type of data shared with third parties, including service providers, and makes these policies prominent and accessible to all users.
- The entity limits the amount and type of data shared with third parties to what is necessary for service delivery without sacrificing the quality of the product.
- The entity does not share user data with third parties for commercial purposes unrelated to service delivery.
- The entity has clear, documented policies in place to limit the purposes for which user data can be shared with third parties and makes these policies prominent and accessible to all users.
- The entity has clear, documented policies in place to explain when and how it may share information with law enforcement or emergency services, and makes these policies prominent and accessible to all users.
- The product handles personal information shared conversationally by users with appropriate care.
- If a user shares personal details or sensitive information about themselves or third parties, the product does not store this information or act on the information in ways that could be harmful.
- The product notifies users of applicable privacy considerations before the user shares personal details or sensitive information about themselves or third parties.