Thomas Linden, Rishabh Khandelwal, Hamza Harkous and Kassem Fawaz
The EU General Data Protection Regulation (GDPR) is one of the most demanding and comprehensive privacy regulations of all time. A year after it went into effect, we study its impact on the landscape of privacy policies online. We conduct the first longitudinal, in-depth, and at-scale assessment of privacy policies before and after the GDPR. We gauge the complete consumption cycle of these policies, from the first user impressions until the compliance assessment. We create a diverse corpus of two sets of 6,278 unique English-language privacy policies from inside and outside the EU, covering their pre-GDPR and the post-GDPR versions. The results of our tests and analyses suggest that the GDPR has been a catalyst for a major overhaul of the privacy policies inside and outside the EU. This overhaul of the policies, manifesting in extensive textual changes, especially for the EU-based websites, comes at mixed benefits to the users.
While the privacy policies have become considerably longer, our user study with 470 participants on Amazon MTurk indicates a significant improvement in the visual representation of privacy policies from the users’ perspective for the EU websites. We further develop a new workflow for the automated assessment of requirements in privacy policies. Using this workflow, we show that privacy policies cover more data practices and are more consistent with seven compliance requirements post the GDPR. We also assess how transparent the organizations are with their privacy practices by performing specificity analysis. In this analysis, we find evidence for positive changes triggered by the GDPR, with the specificity level improving on average. Still, we find the landscape of privacy policies to be in a transitional phase; many policies still do not meet several key GDPR requirements or their improved coverage comes with reduced specificity.