Bulletin: SLS00207

Dear Associates:

EffectiveJuly 1, 2004, any operator of a web site, who collects "personally identifiable information through the Internet about individuals residing in California, who use or visit its commercial Web site" shall conspicuously post its privacy policy on its Web site.  Since residents of California can reach web sites of any Stewart or Stewart affiliated offices, you should consider providing the information required by the statute, as shown below.

The statute, however, does state that you will not be in violation of this law, unless the operator fails to post its privacy policy within 30 days after being notified of noncompliance.

The statute requires that the privacy policy contains all of the following:

   (1) Identify the categories of personally identifiable information that the operator collects through the Web site or online service about individual consumers, who use or visit its commercial Web site or online service, and the categories of third-party persons or entities with whom the operator may share that personally identifiable information.

   (2) If the operator maintains a process for an individual consumer who uses or visits its commercial Web site or online service to review and request changes to any of his or her personally identifiable information that is collected through the Web site or online service, provide a description of that process.

   (3) Describe the process by which the operator notifies consumers, who use or visit its commercial Web site or online service, of material changes to the operator's privacy policy for that Web site or online service.

  (4) Identify its effective date.