For Your Eyes Only You ask for their names, addresses, phone numbers-and customers wonder where they go. Let a privacy statement give your online shoppers peace of mind.

BrainPlay.com takes privacy seriously. An online retailer ofeducational toys and software based in Denver, the company has hada privacy statement on its Web site since its launch two years ago.While the company says protecting the privacy of Internet customersis a courtesy, privacy has become the subject of a heated legaldebate among consumer protection groups, business associations,government agencies and the Clinton administration. Because theInternet gives companies the capability to gather enormous amountsof information about their customers, the worldwide computernetwork is both a marketer's dream and a privacy advocate'snightmare.

For BrainPlay.com, the issue is simple: Protecting privacyimproves its company image and instills trust in its customers."More people are paying attention to privacy issues,"says Srikant Srinivasan, BrainPlay.com's founder and CEO."Consumers today want to know -- and have the right to know --about the companies they're dealing with and how their personalinformation is being used. The good companies are letting themknow."

BrainPlay.com's privacy statement is comprehensive. It saysthe company doesn't sell names, e-mail addresses or otherpersonal information about its customers to third parties.Customers who sign up for BrainPlay.com's monthly e-mailnewsletter, which includes information about special offers, canremove their names from the mailing list at any time. The privacystatement also notes that while the company collects informationabout how visitors use the site, personal information is used onlyto update customers on a product's shipping status or to verifyshipment receipts.

"Customers want to [know] we aren't doing anything withthe information they're giving us," says Doug Smooke,BrainPlay.com's marketing services manager. "We'vealways tried to be as upfront as possible with our customers aboutour policies."

Melissa Campanelli is a technology writer in Brooklyn, NewYork, who has covered technology for Mobile Computing &Communications and Sales & Marketing Managementmagazines. You can reach her at mcampanelli@earthlink.net

Privacy Catches On

Today, many companies doing business on the Web post some sortof privacy policy on their site. While most companies gather andtrack at least some customer information for marketing reasons,only a portion of those collect personal information that can betraced to an individual consumer.

Information can be collected in a few ways: directly, when acustomer provides information voluntarily, such as by registeringat a site or signing a guest book; or indirectly, through a browserand its "cookie" file. (Cookies are computerizedmechanisms that allow Web sites to identify individual Webbrowsers.)

Consistent with its privacy policy, BrainPlay.com doesn'tcollect cookies. "We make sure we let our customers knowwe're not tracking their computers," says Smooke."But there may be a point in time when we start doingit." If BrainPlay.com were to use cookies, it would tell itsWeb customers. "If you're going to track cookies on yoursite, then you have to say that," Smooke says. "You needto tell the user what you're doing."

Online Seal Programs

Another way to build consumer confidence regarding privacy is tojoin an online seal program. These programs are much like a BetterBusiness Bureau for the Web. If a company adheres to certainprivacy principles, it's allowed to display a special seal ofapproval on its Web site.

In general, seal programs are de-sighted to build users'trust in the Internet and to promote principles of fair informationpractices. They indicate to Web users that a company is using theinformation it collects in a responsible way.

Two leading privacy-seal programs are TRUSTe (Trusted UniversalStandards in Electronic Transactions), based in Palo Alto,California, and BBBOnLine, a subsidiary of the Council of BetterBusiness Bureaus (BBB) in Arlington, Virginia. To include either ofthese programs' privacy seals on its Web site, a company mustagree to post a privacy statement that can be easily accessed andunderstood; it must also implement privacy principles that: reflectfair information practices.

The TRUSTe seal is awarded only to Web sites that adhere toTRUSTe's established privacy principles and comply withTRUSTe's verification and consumer resolution processes.TRUSTe's privacy principles say that companies must: informcustomers what personally identifiable information is collected,how it is used and with whom the information wilt be shared, aswell as what the site's policy is on correcting and updatingpersonal information. These principles embody fair informationpractices approved by the U.S. Department of Commerce, the FederalTrade Commission (FTC) and such prominent industry associations asthe Online Privacy Alliance.

When you see our trustmark, you can be assured, among otherthings, that: the Web site will tell you exactly what personalinformation is being gathered about you and how it will beused," says TRUSTe's Anne Jennings. "Many companiesthat join see TRUSTe as a way to build trust with their consumerbase."

TRUSTe's program isn't free. An annual license fee costs$299 for a company with less than $1 million in annual revenue andincreases as a company's annual revenue increases. Once anapplication is received, TRUSTe reviews the Web site and itsprivacy statement, responds with comments and then, if all goeswell, approves it. TRUSTe then e-mails a seal in an electronicfile, with instructions on how to link the seal to TRUSTe'sonline privacy statement. For more information, check outTRUSTe's Web site at http://www.truste.org

The BBBOnLine program is also designed to give consumers theconfidence that their personal information will be safeguarded incyberspace by the companies that participate in the program; itsrequirements are similar to TRUSTe's. BBBOnLine's seal isbacked by the Better Business Bureau; to participate, a companycan't have an unsatisfactory record with the BBB. Allapplicants pay a one time $75 fee. Annual fees vary according toeach company's annual revenue. For more information, visit:http://www.bbbonline.org

BrainPlay.com is a member of both seal programs. "Theprograms helped us formalize our privacy statement, and gave us alittle more credibility," says Smooke. The Better BusinessBureau and TRUSTe are recognized names. Customers can click onthese logos and know we're not just a fly-by-nightorganization. That makes a customer more comfortable shopping withus."

Safety First

If you don't want to join a seal program, it's still agood idea to have a policy statement on your site and to adhere tothe commonly followed, industry -- accepted practices laid out bythe FTC. (See "All's Fair") It's also importantto remember that once a privacy policy is posted on a Web site, itmust be adhered to, or you risk getting into legal trouble.

The Direct Marketing Association (DMA), a trade group that seesthe possibility of government privacy regulation as a major threat,has an online guide to developing a privacy policy statement. Theguide, found at http://www.the-dma.org/topframe/index7.html, encourages companies to complete a questionnaire and create aprivacy policy statement consistent with the association'sPrivacy Principles for Online Marketing, which are similar to theseal programs' principles mentioned previously. In addition,the DMA is working with the FTC on a project to present research onhow many Web sites are publishing privacy policies in accordancewith the FTC's standards. TRUSTe also offers a free PrivacyStatement Wizard at http://www.truste.org/wizard

Although Internet privacy has become a major issue inWashington, few businesses want to see more regulation of Internetcommerce. To avoid the possibility of future regulation, Webmarketers and retailers should voluntarily develop their owninitiatives to protect consumer privacy Respecting the privacy ofWeb users not only helps forestall more regulation but also makesgood business sense in building a bond of trust with your onlinecustomers.

Next Step

In addition to the organizations listed in this column, thefollowing are some useful Internet privacy sources for smallcompanies:

• Association for Interactive Media (http://www.interactivehq.org)

• The Center for Democracy and Technology (http://www.cdt.org)

• U.S. Department of Commerce (http://www.doc.gov)

• Electronic Direct Marketing Association (http://www.doc.gov)

• Electronic Privacy Information Center (http://www.epic.org)

• Federal Trade Commission (http://www.ftc.gov)

• PrivacyExchange.org (http://www.privacyexchange.org)

Contact Sources

BBBOnLine, bbbprivacy@cbbb.bbb.org

BrainPlay.com, (303) 226-6206, doug@brainplay.com

Direct Marketing Association, (202) 955-5030

Federal Trade Commission, (202) 326-2222