Appendix A: Recommendations and responses Update Following the release of the Report of Findings, the Privacy Commissioner filed an application in the Federal Court seeking an order requiring Nexopia to stop retaining personal information indefinitely by adopting a delete function.
Subsequent to the filing of the application, Nexopia underwent a change in ownership. Nexopia's new owner committed to addressing all of the recommendations set out in the Report of Findings by April 30, , including with respect to the issues raised in the court application.
The court application was discontinued on May 29, It alleged that Nexopia was failing to protect the privacy of individuals using its youth-oriented social networking site, in contravention of its obligations under the Personal Information and Protection of Electronic Documents Act the Act.
As a result, our Office has made 24 recommendations to Nexopia to bring it into compliance with various provisions of the Act. In support of its commitment , Nexopia has agreed to provide our Office with regular progress reports, copy documentation and demonstrations of changes to the website, as it addresses the 20 recommendations. These matters remain unresolved as Nexopia has not, at this time, agreed to adopt 4 of our recommendations, or presented any acceptable alternative measures.
We will proceed to address these unresolved issues in accordance with our authorities under the Act. For the purposes of this report, the key elements listed in the Executive Summary under 1. Additional information was provided by the respondent between August and December Our Office has conducted its own extensive reviews of the website. The reviews included visiting the website as a visitor or non-registered user, e. Our Office also conducted a review of domestic and international, academic and government research into youth online privacy.
We issued a preliminary report of investigation to both parties on August 3, In our report to Nexopia, we highlighted numerous concerns and made 24 recommendations.
Nexopia was asked to provide a response to the recommendations within 30 days of the date of the preliminary report of investigation, outlining how it intended to implement them, or provide adequate alternative compliance measures with any supporting evidence showing why implementing our recommendations was not possible.
After an extension to the deadline, Nexopia provided its response to our recommendations on October 3, This report of findings is the culmination of our investigation and consultations with Nexopia. This is a departure from earlier investigations we have conducted against social networking sites, which have not focused on users under the age of By way of example, Facebook users under the age of 18 are subject to different privacy defaults and searchability and this approach was the result of a business decision taken by the company itself.
Company Profile Nexopia. It has over 1. Individuals wishing to register with Nexopia must be at least 13 years of age. The second largest user demographic group on the site are individuals aged years, perhaps users who joined the site as teenagers in its earlier days Footnote 2.
Nexopia states that its users come to the website to meet new people, express themselves and achieve social prominence. Users express themselves on Nexopia. The website does not charge a fee for regular membership. Definitions The following terms used throughout this report are defined as follows: The information is the minimum visible to other Nexopia users and visitors in a user profile: Specifically, they alleged that Nexopia had no system in place to block public searches of the profiles of its youth users when compared to another popular social networking site , and that Nexopia did not give users the option to hide their profiles from the general public.
They alleged that the site required certain pieces of personal information to be disclosed to the public and that even when a user restricted their privacy settings to the most privacy-protective option, this personal information would always be disclosed to the general public in a search. They submitted that it was difficult for users to change their visibility and privacy settings, as these settings did not exist in a single place.
If users wished to edit their settings to be more privacy protective, they were required to edit the settings under several different profile editing panels or had to access multiple tabs under the Preferences function. The complainants believed that a centralized page for users to view and modify their privacy settings, in addition to the current ability to change settings at a granular level, was preferable.
Summary of Investigation External search engines display personal information from Nexopia. We were able to access the full content of many of the user profiles obtained from these searches. We conducted searches using three well-known search engines. Simple search criteria was adopted in each case, e.
By way of illustration, one search using the above criteria yielded results. Visitors to Nexopia. One search can generate many corresponding user profiles. Depending on the number of profiles identified in a search, visitors can then look at additional pages of profile summaries. Up to profiles can be generated and displayed in a single search.
In the same section, Nexopia explains that the site allows embedded searches by real name, usernames and email addresses. Nexopia also has a Safety Page, which provides advice for users of online communities. In one section it states the following: Comments are also visible to the public and are not the place to share any personal information — use private messages instead.
At the time, all social networks were open in this manner and it has remained an open network to this day. We observed that even when a user sets privacy preferences for each block of information in their user profile to the most restrictive setting, i.
The hide profile function blocks a user profile from visitors in its entirety. It is not mandatory for a user to include a profile picture in their profile.
However, users wishing to take advantage of the facility and add profile pictures must adhere to certain Nexopia guidelines, in order for their pictures to be accepted. They must be recognizable pictures of the user. Profile pictures containing personal information such as school identity, drivers licences, full names, addresses and telephone numbers are not acceptable. Pictures of celebrities, landscapes, pets, or groups of individuals are only acceptable if the user is included in the picture, is clearly identifiable and the picture has not been computer edited.
Once added, a user can remove a profile picture from their profile at any time, without difficulty. Nexopia argued that requiring profile pictures to be of real people, encourages greater security on its site, e. The three principal blocks of information in a user profile are Basics, Contact and Interests.
In addition to being able to set privacy settings at the block level, Nexopia allows users to establish more refined control over the visibility of certain individual items of personal information contained within a single block. Users posting information into the Basics block can choose to input their real names, height, weight, sexual orientation, dating status, living situation, location and school.
The name fields are left blank by default. The website allows users the ability to hide some information: The Contact block allows users to post up to 26 user identifiers for instant messaging programs, social networking websites, sites featuring media content, personal blog and gaming sites. Users are not able to override the overall block privacy setting in favour of customized privacy protection for specific items.
In the Interests block, users build their profile by choosing from a variety of interests listed under 14 different categories. As with the Contact block, the Interests block does not allow users to override the overall block setting in favour of customized privacy protection for specific items. During the course of our investigation, we noted that a user could establish privacy settings for their friends list.
However, unlike its description of the other forms of personal information stated above, Nexopia does not indicate that establishing privacy settings for a friends list is possible within its Help function, Frequently Asked Questions, or its User Profile user guide. A user can change their privacy preferences in two ways: During our investigation, we tested both methods to amend the privacy settings of the user profiles we created for our test accounts.
From the Preferences tab, there are a large number of controls to manage privacy and these are found under the following tabs: General, My Pages and Accounts.
For all of the privacy controls within the Preferences function, the default settings were set by Nexopia to the widest visibility possible. Under the General tab, users can control publishing content to public pages of the site, only accept messages from friends, ignore messages from individuals outside a designated age range and control the parameters used when browsing the user search facility.
The default for the hide profile function is for it to be deactivated, so that user profiles can be found and viewed by visitors. Under the Accounts tab, users can allow others to search them by either their real name or their email address. Forum postings are visible to everyone and cannot be deleted. No notification is given either before a selection is considered, or through a confirmation message, once a block of information has been completed.
In addition, you may choose to hide your birth date. However, this information is still used to calculate your age. However, the Policy does not provide a clear description of the default settings, describe the implications of choosing a particular setting, or of selecting an alternative default. Nexopia user trends in privacy settings Based on our analysis of statistics that Nexopia provided during our investigation, it appears that a very small percentage of users change the default privacy settings for the Basic, Contact and Interests blocks.
Among the , registered youth users i. Nexopia qualified the accuracy of the information they provided, as some youth self-certify at an age above their true age; e. These individuals are not accounted for in the above statistics. Nexopia does not regularly monitor the number of users who change their privacy preferences from the default privacy settings. The company claims that its website is an open network which competes in the same market as other community-driven sites open to public viewing.
The Facebook investigation sets expectations for the privacy practices of other social networking sites.
Nexopia A privacy complaint was filed against the Canadian social networking site Nexopia in January The six violations are outlined below: User profiles and personal information are disclosed to the general public. Non-member visitors can easily access sensitive information, including personal information, comments, blogs, messages and photos. Even with the highest privacy-protective setting on Nexopia, some person information i.
While Nexopia uses targeted advertising to generate income, it does not adequately explain its advertising practices. Users do not have meaningful consent as to how their personal information will be used or disclosed.
Users do not have the ability to opt-out of the targeted advertising program. Nexopia fails to incorporate this practice into its information collecting procedures.
Current Nexopia practices regarding the transferring and sharing of personal information with third parties is not transparent. For instance, if Nexopia members send email invitations to their non-member friends, Nexopia stores the email addresses the members provide for future use, although the non-members have not given consent to the collection and use of their email addresses.
They also do not have the option to unsubscribe from Nexopia invitations or emails. The PIAC noted that the member search engine is a worrisome tool, as it permits a fine-grained search of its members. For example, the advanced search can allow an individual to search for females between the ages of 13 and 16 who live in a particular city, or attend a specific school and have certain interests.
It is clear that the search tool does not respect youth privacy. Joint Resolution In response to child and youth privacy concerns, the federal Privacy Commissioner and provincial privacy oversight officials issued a joint resolution , expressing commitment to improving online privacy standards for children and youth.
The Offices advocated an education-based approach that would be upheld by partnerships between commissioners, governments, industry and organizations.
Some of the steps to be taken included: Collaboration between Commissioners and ombudsmen on public education activities. Industry guidance for better privacy practices. How to start dating over Casual dating halifax county.
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