Privacy Policies are Great -- for PhDs

(MoneyWatch)  Major Internet companies say that they inform their customers about privacy issues through specially written policies. What they don't say is that more often than not consumers would need college undergraduate educations or higher to easily wade through the verbiage.

When the House sent letters to 31 major Internet-related companies asking them about their privacy practices, included was a question of whether the businesses tell clients what they are doing. The common answer was, "Certainly, we proudly post our privacy policy." I wondered about how user friendly those policies might be, so ran many through online readability software. The result: consumers need a whole lot of education to be able to casually read through what they find.

To give a visceral sense of grade reading levels, I went to a site of Harry McLaughlin, inventor of the SMOG readability index, and looked pairs of scores and comparable reading material:

SMOG Grade Level	Reading Material Example
0-6	Soap Opera Weekly
7	True Confessions
8	Ladies Home Journal
9	Reader's Digest
10	Newsweek
11	Sports Illustrated
12	Time Magazine
13-15	New York Times
16	Atlantic Monthly
17-18	Harvard Business Review
19+	IRS Code

I chose 23 corporate privacy policies from companies that received letters from the House, skipping ones where I could not readily find the policy, the policy only covered use of the web site, or the site was unavailable.

An online site that calculates readability scores under various schemes provided the basic data. The Gunning Fog, SMOG, and Flesh Kincaid Grade Level scores all gave approximate years of education necessarily to comprehend the policies on a first read. Because the three scores for any given policy were fairly close, I averaged them.

Here are the companies (each name is linked to the policy URL), the approximate length of the policies, and the average grade levels:

Company	Policy Length (in Words)	Average Grade Level
AOL	2,475	17.37
AT&T	3,051	13.63
Bresnan Communications	3,402	18.56
Bright House Networks	1,241	13.9
CableOne	1,156	18.59
CenturyTel	4,338	12.9
Charter Communications	3,873	16.33
Comcast Communications	5,428	17.33
Cox Communications	5,371	14.19
Earthlink	1,660	14.00
Google	1,937	16.82
Insight Communications	1,909	20.78
Juno	3,276	17.93
Microsoft	4,221	15.1
NetZero	3,867	15.02
Qwest	1,764	12.33
RCN Corporation	4,941	17.08
Suddenlink Communications	5,947	15.09
Time Warner Cable	2,958	18.5
Verizon	2,734	14.34
WideOpen West	5,828	16.09
XO Communications	2,296	15.12
Yahoo	5,502	11.93

Winner of the Most Readable category is Yahoo, whose privacy policy only required a roughly high school/Time level of comprehension -- good thing, because that amount of text could command a good ten pages of the magazine.

The Great Complicator is Insight Communication, which at 20.78 years is clearly a taxing read. Most Compact Twists and Turns has to be CableOne; at 1,156 words, it still is nearly in the tax code class.

For some perspective, a couple of years ago, the Securities and Exchange Commission informed publicly-held companies that the descriptions of executive compensation in proxy statements had to be put into plain English. To the SEC, that means a reading level at about the level of the Readers Digest -- about three years lower than even Yahoo's score.

If corporations can be reasonably expected to simply state what the CEO of a company makes, surely they should be able to work toward the same goal when it comes to privacy. If not, maybe they should send subscriptions of the Harvard Business Review to all their customers, because clearly there must be untapped intellectual power out there.

Egyptian parchment image via morguefile.com user chelle, use under site standard license.