Privacy Officers Network
04 July 2002
EU draft directive on E-Communications
Jessica Hendrie-Liano, Company Lawyer, Freeserve.com plc
- How to develop a workable e-marketing policy in light of the new EU draft directive on E-communications?
Points for members to discuss:
- What can we learn from countries with similar permission based laws for e-communications?
- Opting-in for e-mail and other forms of marketing – Are there any practical problems about a uniform policy for:
- different countries?
- different media channels?
- Problems of changing from opt-out to opt-in
- rewording of contracts for providers of mobile device services and content
- online shopping contracts
- wording of privacy policies
- How do companies develop a permission- based marketing system? How do you develop a privacy sensitive culture in the marketing department?
- Interpreting the boundaries of a “soft opt-in” (marketing to existing customers and customers for similar products and services)
- Marketing to:
- other members of your group of companies
- companies in which you have a majority holding
- How to avoid ISPs filtering out legitimate bulk e-mail identified as spam?
- How to interpret ‘clear and comprehensive’ information about cookies?
- How should companies inform web users about the existence of cookies and how they may be disabled?
- The advantages and disadvantages of P3P for blocking cookies?
How to develop and implement a global data protection policy
Points for discussion:
- Where to start: A blank sheet or a current country policy?
- Setting objectives and agreeing scope: Reconciling different national legal cultures with top management’s business objectives
- How best to obtain feedback on your draft policy from various stakeholders?
- If you are not sure whether your policy is compatible with a country’s national privacy law, what practical actions do you take to determine whether or not it is compatible?
- What tools do you use? Intranet, staff notices, training sessions, annual report, website?