The Word of Mouth Marketing Association ("WOMMA") recognizes the importance of protecting privacy across all marketing and communications channels. While privacy is a multi-faceted issue, WOMMA believes that transparency and choice are at the heart of establishing and sustaining the meaningful connection between brands and consumers.
To assist its members and the word of mouth/social media marketing industry, WOMMA proposes the following Guidance for implementation into a company's compliance philosophy. These Guidance, relating to the core business practices of brands and their partners, are submitted as aspirational principles designed to incorporate privacy protections into a company's culture in a meaningful way.
I. Transparency, Openness, and Honesty:
Brands should be open and honest about Personally Identifiable Information ("PII") that they are collecting, using and sharing from consumers. PII is to be interpreted broadly, as encompassing not only any type of information that could be used to uniquely identify a person - including, for example, a person's name, address, phone number, birth date, social security number, or credit card or bank account numbers - but "personal information" that can be used to identify or locate a person. Brands should communicate with consumers in a clear and conspicuous manner, and in a language that is understandable to the reasonable consumer or intended audience.
II. Limiting Use:
Brands should use PII collected from or about consumers for the purposes that they have clearly communicated.
III. Relevance and Necessity:
Brands should collect PII that is relevant and necessary to accomplish the specified purposes.
Brands should not retain PII for longer than necessary to fulfill the specified purposes or to otherwise meet legal requirements.
V. Consumer Participation:
Brands should seek to provide mechanisms for appropriate consumer review, access, and correction of PII that they maintain, to the extent practicable.
VI. Data Quality and Integrity:
Brands should strive to keep PII about consumers accurate and up-to-date.
Brands should employ measures to protect PII based on the reasonable expectations of their customers, the sensitivity of the information, the nature of the brand's business, the potential of risks the brand faces, and the reasonable protections available to the brand. Brands should require that business partners who collect or use such PII on the brand's behalf also adopt appropriate security measures.
VIII. Accountability and Monitoring:
Brands should be accountable for complying with these principles, by providing consumers with a readily accessible means to express concerns or complaints regarding adherence to these principles, and brands should respond to such concerns or complaints appropriately.
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