Australian Privacy Principles
Under privacy law in Australia, businesses must include certain information that will allow people to be informed about how their personal information will be handled if they choose to interact with the business. The Commissioner distributed gold stars to a select few for their stellar privacy policies but noted that some organised remained firmly in the sin-bin. Organisations fell down when relevant information took too long to locate, or when they skirted around the issue of how information could be accessed and corrected. Black marks were also given when information on how a privacy complaint could be made or how information was protected was fudged or unclear.
The result is calculated using the formula below:
Grade Level = 0.39 (total words/total sentences) + 11.8 (total syllables/total words) – 15.59
For an instrument used to measure Plain English, the level of irony of using the formula above probably tops the scale.
Tips from the Commissioner
- Seek input from all areas of your entity including your public relations department, which may have ideas about innovative formats for better communicating the policy, for example, through video or other mechanisms relevant to the communication channel (paper, telephone, email, online) that you are using;
- Focus on what is important to the reader. Do not try to cover everything in minute detail;
- Keep it simple. Use simple language and test readability in content and format against external standards such as the Flesch-Kincaid grade level;
- Consider having more than one policy. For large or complex entities, consider whether you need to have more than one policy (for different parts of your operation or business, or different functions or activities).”