Abstract The EU General Data Protection Regulation (GDPR) is one of the most demanding and comprehensive privacy regulations of all time. A year after it went into effect, we study its impact on the landscape of privacy policies online. We conduct the first longitudinal, in-depth, and at-scale assessment of privacy policies before and after the GDPR. We gauge the complete consumption cycle of these policies, from the first user impressions until the compliance assessment. We create a diverse corpus of two sets of 6,278 unique English-language privacy policies from inside and outside the EU, covering their pre-GDPR and the post-GDPR versions. The results of our tests and analyses suggest that the GDPR has been a catalyst for a major overhaul of the privacy policies inside and outside the EU. This overhaul of the policies, manifesting in extensive textual changes, especially for the EU-based websites, comes at mixed benefits to the users. While the privacy policies have become considerably longer, our user study with 470 participants on Amazon MTurk indicates a significant improvement in the visual representation of privacy policies from the users’ perspective for the EU websites. We further develop a new workflow for the automated assessment of requirements in privacy policies. Using this workflow, we show that privacy policies cover more data practices and are more consistent with seven compliance requirements post the GDPR. We also assess how transparent the organizations are with their privacy practices by performing specificity analysis. In this analysis, we find evidence for positive changes triggered by the GDPR, with the specificity level improving on average. Still, we find the landscape of privacy policies to be in a transitional phase; many policies still do not meet several key GDPR requirements or their improved coverage comes with reduced specificity.
more »
« less
Privacy Now or Never: Large-Scale Extraction and Analysis of Dates in Privacy Policy Text
The General Data Protection Regulation (GDPR) and other recent privacy laws require organizations to post their privacy policies, and place specific expectations on organisations' privacy practices. Privacy policies take the form of documents written in natural language, and one of the expectations placed upon them is that they remain up to date. To investigate legal compliance with this recency requirement at a large scale, we create a novel pipeline that includes crawling, regex-based extraction, candidate date classification and date object creation to extract updated and effective dates from privacy policies written in English. We then analyze patterns in policy dates using four web crawls and find that only about 40% of privacy policies online contain a date, thereby making it difficult to assess their regulatory compliance. We also find that updates in privacy policies are temporally concentrated around passage of laws regulating digital privacy (such as the GDPR), and that more popular domains are more likely to have policy dates as well as more likely to update their policies regularly.
more »
« less
- NSF-PAR ID:
- 10505060
- Publisher / Repository:
- ACM
- Date Published:
- Journal Name:
- DocEng '23: Proceedings of the ACM Symposium on Document Engineering 2023
- ISBN:
- 9798400700279
- Page Range / eLocation ID:
- 1 to 4
- Format(s):
- Medium: X
- Location:
- Limerick, Ireland
- Sponsoring Org:
- National Science Foundation
More Like this
-
-
Legal jurisdictions around the world require organisations to post privacy policies on their websites. However, in spite of laws such as GDPR and CCPA reinforcing this requirement, organisations sometimes do not comply, and a variety of semi-compliant failure modes exist. To investigate the landscape of web privacy policies, we crawl the privacy policies from 7 million organisation websites with the goal of identifying when policies are unavailable. We conduct a large-scale investigation of the availability of privacy policies and identify potential reasons for unavailability such as dead links, documents with empty content, documents that consist solely of placeholder text, and documents unavailable in the specific languages offered by their respective websites. We estimate the frequencies of these failure modes and the overall unavailability of privacy policies on the web and find that privacy policies URLs are only available in 34% of websites. Further, 1.37% of these URLs are broken links and 1.23% of the valid links lead to pages without a policy. Further, to enable investigation of privacy policies at scale, we use the capture-recapture technique to estimate the total number of English language privacy policies on the web and the distribution of these documents across top level domains and sectors of commerce. We estimate the lower bound on the number of English language privacy policies to be around 3 million. Finally, we release the CoLIPPs Corpus containing around 600k policies and their metadata consisting of policy URL, length, readability, sector of commerce, and policy crawl date.more » « less
-
null (Ed.)The European Union’s General Data Protection Regulation (GDPR) has compelled businesses and other organizations to update their privacy policies to state specific information about their data practices. Simultaneously, researchers in natural language processing (NLP) have developed corpora and annotation schemes for extracting salient information from privacy policies, often independently of specific laws. To connect existing NLP research on privacy policies with the GDPR, we introduce a mapping from GDPR provisions to the OPP-115 annotation scheme, which serves as the basis for a growing number of projects to automatically classify privacy policy text. We show that assumptions made in the annotation scheme about the essential topics for a privacy policy reflect many of the same topics that the GDPR requires in these documents. This suggests that OPP-115 continues to be representative of the anatomy of a legally compliant privacy policy, and that the legal assumptions behind it represent the elements of data processing that ought to be disclosed within a policy for transparency. The correspondences we show between OPP-115 and the GDPR suggest the feasibility of bridging existing computational and legal research on privacy policies, benefiting both areas.more » « less
-
Villata, S. (Ed.)The European Union’s General Data Protection Regulation (GDPR) has compelled businesses and other organizations to update their privacy policies to state specific information about their data practices. Simultaneously, researchers in natural language processing (NLP) have developed corpora and annotation schemes for extracting salient information from privacy policies, often independently of specific laws. To connect existing NLP research on privacy policies with the GDPR, we introduce a mapping from GDPR provisions to the OPP-115 annotation scheme, which serves as the basis for a growing number of projects to automatically classify privacy policy text. We show that assumptions made in the annotation scheme about the essential topics for a privacy policy reflect many of the same topics that the GDPR requires in these documents. This suggests that OPP-115 continues to be representative of the anatomy of a legally compliant privacy policy, and that the legal assumptions behind it represent the elements of data processing that ought to be disclosed within a policy for transparency. The correspondences we show between OPP-115 and the GDPR suggest the feasibility of bridging existing computational and legal research on privacy policies, benefiting both areas.more » « less
-
The European General Data Protection Regulation (GDPR) mandates a data controller (e.g., an app developer) to provide all information specified in Articles (Arts.) 13 and 14 to data subjects (e.g., app users) regarding how their data are being processed and what are their rights. While some studies have started to detect the fulfillment of GDPR requirements in a privacy policy, their exploration only focused on a subset of mandatory GDPR requirements. In this paper, our goal is to explore the state of GDPR-completeness violations in mobile apps' privacy policies. To achieve our goal, we design the PolicyChecker framework by taking a rule and semantic role based approach. PolicyChecker automatically detects completeness violations in privacy policies based not only on all mandatory GDPR requirements but also on all if-applicable GDPR requirements that will become mandatory under specific conditions. Using PolicyChecker, we conduct the first large-scale GDPR-completeness violation study on 205,973 privacy policies of Android apps in the UK Google Play store. PolicyChecker identified 163,068 (79.2%) privacy policies containing data collection statements; therefore, such policies are regulated by GDPR requirements. However, the majority (99.3%) of them failed to achieve the GDPR-completeness with at least one unsatisfied requirement; 98.1% of them had at least one unsatisfied mandatory requirement, while 73.0% of them had at least one unsatisfied if-applicable requirement logic chain. We conjecture that controllers' lack of understanding of some GDPR requirements and their poor practices in composing a privacy policy can be the potential major causes behind the GDPR-completeness violations. We further discuss recommendations for app developers to improve the completeness of their apps' privacy policies to provide a more transparent personal data processing environment to users.more » « less
- Free Publicly Accessible Full Text
-
Accepted Manuscript1.0
- Conference Paper:
- https://doi.org/10.1145/3573128.3609342
