Privacy Washing: Detecting Internal Contradictions in Privacy Policies

Abstract:Privacy policies may contain internal contradictions in which commitments are undermined by practices documented elsewhere in the same policy. We operationalize this phenomenon, privacy washing, through a four-stage pipeline: statement extraction, compatibility filtering and natural language inference screening, multi-model judge verification, and thematic analysis, with contradictions confirmed by majority vote of a three-model LLM panel. Applied to two corpora of website privacy policies, 123 collected in 2026 (OPPT) and 115 collected in 2015 (OPP-115), the pipeline finds the same category patterns recurring across the 11-year gap, with third-party sharing contradictions the majority of confirmed cases in each primary run, consistent with structural factors in policy composition rather than necessarily intentional deception. At least one panel-confirmed contradiction appears in 12.2% of OPPT companies (15/123; 9.8% excluding legacy pairs) and 36.5% of OPP-115 companies (42/115). A stability re-run seven months later, with a fully separated configuration (new extraction models, judges from three Chinese providers absent from both corpora, matched filters, no judge-submission similarity threshold), reproduces the OPPT prevalence under the original protocol (13.0% vs. 12.2%), finds sub-threshold pairs confirm at rates of the same order as those above (raising prevalence to 20.3% and 40.9%), and shows the third-party majority is panel-sensitive while the recurrence of the same category pairs is not. Two caveats govern all figures: panel verdicts are not validated against human expert judgment, so precision is unknown and prevalence figures are lower bounds; and the two primary runs used different filter configurations, so their prevalence difference is not interpretable as a corpus or era effect (the matched re-run reduces the gap to roughly twofold but does not eliminate it).

Computers and Society (cs.CY); Computation and Language (cs.CL)

arXiv:2609.02055 [cs.CY]

(or arXiv:2609.02055v1 [cs.CY] for this version)

https://doi.org/10.48550/arXiv.2609.02055 Focus to learn more arXiv-issued DOI via DataCite (pending registration)

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