Privacy by Default

Criteria: The default settings in this product prioritize my privacy; to give up privacy, I actually need to change the settings.

See the test in action:

• Smart lock
• Smart pressure cooker
• Smart baby monitor

Methodology for Assessing Each Indicator

1) Targeted advertising is off by default.

• Determine whether the product or service hosts advertising or sends ads to users.
• If the product or service hosts or sends ads, look for places where a user might be able to control privacy settings.
  • If a product has multiple interfaces, such as a mobile app, a web app, or an in-device interface, make sure to investigate all of them.
  • Privacy settings may be in a “profile” section of an app, or under the app’s “settings.”
  • If the manufacturer has a website that users may visit, look at the website’s privacy policy for information about targeted advertising.
• If there is a privacy setting for “targeted advertising” (which may also be called “interest-based” or “behavioral” advertising), note whether the setting is on or off for a new user.
• Look in the manufacturer’s legal documents for a list of how it uses user data.
  • Note whether “targeted advertising” or a similar term is listed as a possible use of user data.
• If the manufacturer does not host or display ads or if it only hosts or displays ads that are not targeted (e.g. contextual), mark PASS.
• If the manufacturer lists targeted advertising as a way it uses user data in its legal documents, and there is a user setting for controlling it that is set to “off” for a new user, mark PASS.
• If the manufacturer lists targeted advertising as a way it uses user data in its legal documents, and there is no setting for controlling it, or if there is a user setting for controlling it but it is set to “on” for a new user, mark FAIL.

2) User interface settings which are optimal for privacy are set by default.

• Look for places where a user might be able to control their privacy settings.
  • If a product has multiple interfaces, such as a mobile app, a web app, or an in-device interface, make sure to investigate all of them.
  • Privacy settings may be in a “profile” section of an app, or under the app’s “settings.”
• Identify all of the settings that could have an effect on the privacy of a user’s personal information, (e.g., collection of location, sharing with third parties, or usage analytics) and note how those settings are configured for a brand new user.
• If all privacy settings identified are set by default to the choice that limits the amount of personal information shared and maximizes the user’s privacy, mark PASS.
• If some or all of the settings identified are set by default to choices that do not maximize the user’s privacy, mark FAIL.
• If there are no visible settings that would enable the user to control data collection or use that may affect the user’s privacy, mark FAIL.