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Last week, California's Attorney General published some guidance to aid organizations in complying with the recent changes in California privacy law. The portion of the guidance that relates to the newest requirements offers the following general recommendations:
- Make it easy for a consumer to find the section in which you describe your policy regarding online tracking by labeling it, for example: "How We Respond to Do Not Track Signals," "Online Tracking" or "Do Not Track Disclosures."
- Describe how you respond to a browser’s Do Not Track signal or to other such mechanisms. This is more transparent than linking to a "choice program."
- State whether other parties are or may be collecting personally identifiable information of consumers while they are on your site or service.
- Explain your uses of personally identifiable information beyond what is necessary for fulfilling a customer transaction or for the basic functionality of an online service.
- Whenever possible, provide a link to the privacy policies of third parties with whom you share personally identifiable information.