Notice and Disclosure

	Notice should be provided at the point of data collection before the collection occurs
	The following items must be disclosed to the individual
	The entity collecting the data What data is collected How data is collected How data will be used How the individual can exercise choice over personal data With whom data will be shared Steps taken to ensure data security and accuracy
	"Secondary uses" are uses of the data other than for the primary purpose for which it is provided. All secondary uses must be disclosed to the individual.
	Full disclosure of all costs

Choice/Consent

	Individuals must be given choice over secondary uses of personal information.
	Two competing models
	Opt-out Individuals not opting-out provide implicit consent for use of data. Companies assume individuals want to receive future emails unless they opt-out. Opt-in: Individuals opting-in give explicit consent for use of their data Consumers are in control of their personal information. Consumers are asked for their permission to receive emails from sending companies and partners. Mediasmith supports the opt-in model.

Access/Participation:

The individual must have the right to view the profile and make corrections

Integrity/Security:

Data collectors must ensure that the steps are taken to ensure that the data is accurate and stored in a secure manner.

Enforcement/Redress:

There must be a mechanism to enforce privacy guidelines and provide consumers redress for .violations

For more on this important topic, see our white paper,
"DoubleClick, Cookies and Privacy".