For US-based companies, please note that privacy policy violations are also violations of Section 5 of the FTC Act which prohibit deceptive practices. This could open up the company to prosecution and fine by the FTC.

For example, please see the settlement of the recent FTC action against Gateway Learning.

http://www.ftc.gov/opa/2004/07/gateway.htm

Stacy Martin
Plaxo Privacy Officer
privacy @t plaxo.com