Need a Refresher on What We have Discussed:
- Lesson 1 – Getting Started
- Lesson 2 – Writing the First Paragraph
- Lesson 3 – What Information Are You Collecting?
How will you be using the information you collect on your site? Are you using a targeted marketing auto responder? Do you have an email newsletter? Do you plan to sell your list? It is important you let your users know how you will be using their information. Just like when we discussed the Personal Information, you want to make sure you use qualifying language and that your list is not inclusive.
Example from The Outsourced Associate
So, let’s look at an example from the new TOA policy:
Any of the personal data collected will be used, primarily, to provide the services offered by TOA in an effective and personalized manner. Your personal information may be used to:
- Provide services and customer support as requested, including confirming emails related to the website services, reminders and transactions.
- Facilitate communication between interested parties registered on the Site.
- Customize your experience and otherwise measure and improve the services and the Site.
- Keep you informed about targeted marketing, service updates, and promotional offers based on your communication preferences. (There is an option to opt-out of email marketing communications)
- Compare information for accuracy and verify it with third parties.
- Measure consumer interest in the products and services offered on the Site or otherwise by TOA.
- Help promote a safe service and detect and prevent error, fraud, and other potentially prohibited or illegal activity.
- To collect fees.
- To customize an initial consultation through the information provided.
- As otherwise described at the time of collection.
Unpacking the Language
As with the personal information section, we are talking about what you may do. In this case, I used the qualifier “primarily”. I am leaving myself enough wiggle room to do things other than the what is on the list I have included. So, let’s talk a bit about the list. Keep in mind, with TOA, I am still playing with what I will be doing with the site and how my online offerings will work with my offline legal services. As such, I have included a relatively comprehensive list of all the ways I might use the information provided through the site. Also, with the TOA site, I am considering ways to connect people to other service providers or, potentially, other users. So, I have included all of that information.
Notice that I include information on what I may provide and communications I may make without going to any specific detail on email policy. I am still playing with what I may do here, but the point is that you let your users know they will have an option to opt out once they get to your email list. Then, make sure the opt-out option actually exists with your e-mail provider. And make sure you honor their request to opt-out.
Notice how I also include information about how the service will be better because of your information. I can provide a customized initial consultation because I can do my homework on you when I learn more about you and your business, I can learn more about what matters to the users of my site and make sure the content is helpful and the services offered are relevant.
Protecting your Business For Growth
Do you have to collect if someone fails to pay you? No. You are not required to use the information to collect your fees. You are not required to do anything. But, your legal needs to be there if you need it. So, provide the information about how you will use the fees and do not be afraid of it. After all, it is the right thing to do. And it’s the law.
Legal to English Example
Now, for a more plain spoken approach, let’s see how the LTE policy handles this.
This policy, as we have seen for the past couple of weeks is much more conversational. Notice a couple of things I do in this one. I talk about the email newsletter and how I use your name and email address. I also remind you that the site is owned by my law practice and you may see service or product offerings related to my firm. I let you know that so any marketing pieces do not look like I have sold the list. I do not ever plan to do any hard sells or hard promotions with the information I gain from LTE, that’s not the purpose for the site. It is possible, however, that people discover my firm through LTE and the information I have from them came from this site, so it is important I am open and honest about the connection between the two sites and how that information may be used.
We are approaching the end of this series! There are only a few more parts of your policy to cover. Tomorrow, we will talk about disclosure and how you are actually “sharing” the information you collect with someone else, no matter what your signup form says.
So, hang in there, we are almost done. Also remember, when we are through, I will give you the templates we are building so you can work with them for your own site.