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  3. The privacy policy names other vendors than the site uses
  4. The privacy policy names other vendors than the site contacts

Privacy finding

The privacy policy names other vendors than the site contacts

Privacy Warning Severity: High

Part of the audit The privacy policy names other vendors than the site uses. Finding id: privacy.policyVsVendors.

What it costs you

The policy is your statement of who receives visitor data. A vendor the browser contacts and the policy leaves out is a gap anyone can show with a network log.

What to do

Compare the list with the processing register and bring the policy up to date, or remove the tool.

What it checks

  • Vendor in use but not named
  • Vendor named but no longer used
  • Transfer country not mentioned
  • Policy says no third parties

How to fix it

Bring the policy and the site in line

  1. Give the list of hosts and vendors to the person who keeps the processing register.
  2. Vendor in use and not named: add it to the policy with its country, or remove the tool from the site.
  3. Vendor named and not in use: confirm with the team that owned it, then take it out of the policy.
  4. A policy that says no third parties are involved needs rewording as long as the pages contact any.

How to check: Crawl the site again after the policy changed. The vendor no longer appears in this rule.

A real case

An audit of the data flows on one million websites and of over 200,000 of their privacy policies found that fewer than 15% of the flows to third parties were disclosed in the policy.

Source: Timothy Libert, An Automated Approach to Auditing Disclosure of Third-Party Data Collection in Website Privacy Policies, WWW 2018

How to verify by hand

The data protection officer's processing register.

What this relies on

The observed vendors are real; the policy was not updated when marketing added a tool.

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