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What General Data Collection Policy Should We Carefully Follow

Our compliance department has established strict protocols for collecting data from the public web. 

Principle 1:Barkingdata should establish teams and procedures to address any incoming complaints or notices from third parties.Barkingdata should establish internal company policies to ensure that incoming complaints or notices are quickly escalated to the appropriate team.

Identify and Escalate Potential Complaints

Complaints may be received in many forms, including a phone call or email. While the content of these communications may not be consistent or complete it is the responsibility of the individuals tasked with execution of this policy (“Designee” noted below) to collect the information necessary to conduct an investigation and make a determination as to the appropriate course of action. It is the responsibility of each employee to report any potential complaint communication to the Designee. Communications which may be considered a complaint are any containing inquires or requests on data collection practices in general or inquires or requests on specific websites.

Contacts for Escalation

Barkingdata  has designated the Managing Director of Barkingdata and the Chief Information Officer of Barkingdata jointly as designees (“Designees”) to accept, validate, investigate, respond and ultimately resolve each complaint received. An email address of info@Barkingdata.com has been established to receive any compliance related issues.

Principle 2:Barkingdata should ensure that it has provided accurate and updated contact information to third parties from whom it purchases Internet services used to collect data.

Barkingdata must ensure all technology providers including bandwidth, proxy and any computing or hosting providers are provided with current contact information to allow communication of any potential complaint received through any of these providers. 

Principle 3:Barkingdata mustn’t use any logins to collect data.

Barkingdata must ensure that the robot doesn’t create any type of logins to collect data from websites or mobile apps. 

Principle 4: Barkingdata mustn’t collect personally identifiable information about individuals.

Barkingdata mustn’t collect Personally Identifiable Information (PII), personal health information or personal financial information from or about any individuals as a matter of policy.  Barkingdata can only collect information that is publicly available to an ordinary user of a browser or mobile device.

Principle 5: Barkingdata should access websites in a way that does not interfere with the website or impose undue burden on the site’s operation. Barkingdata also must not reverse engineer, decompile or otherwise disrupt the integrity or security of a website.

Caution is taken in the creation and ongoing operation of our web crawling operation to minimize impact to a given site.

Initial Traffic Guidelines

Each development specification document shall include a traffic target to determine an appropriate level of requests to be made to a website within a given period of time.  Traffic to a given website should never exceed 0.1% of the total traffic of the website.

Ongoing Traffic Assessment

As no standard traffic benchmarking exists which include desktop, mobile, international and robot traffic comparing our robot traffic versus a benchmark is not possible. In no case will traffic to a given site exceed 60 requests within any given 60 seconds.

Principle 6: Barkingdata should stay abreast of the law relating to Internet data collection practices and, periodically, should confer with counsel to assess its policies in light of developments in the law.

It shall be the responsibility of the Designees to confer periodically with counsel on developments in the law on data collection and related areas. Designees shall document any updates or amendments to this policy and indicate why such changes are being enacted.

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