A Roadmap for FTC Compliance Requirements for Mobile Apps

April 9, 2013 Pivotal Labs

In a staff report released on February 1, the U.S. Federal Trade Commission (FTC) offered recommendations to protect consumers including just-in-time disclosures, privacy icons, and the creation of a privacy dashboard. This is important information for anyone seeking to improve mobile apps. While FTC recommendations don’t have the force of law, they reveal issues of concern to the FTC and following these guidelines can save time later if any of them become law.

Barry Benjamin and Jeremy Schachter, writing in Lexology, provided a detailed summary of the FTC report, which suggested that mobile app platforms, such as iOS and Android, provide the following elements:

  • Just-in-time disclosures. When an app is about to access some private information, a dialog box often appears to tell the user that it’s going to happen. These disclosures are most often seen with relation to apps that use geolocation: “This App Wants To Look At Your Location Information.” The user can then say yes or no.
  • Privacy icons. An icon appears when the app is accessing location information. The FTC thinks devices should display such icons.
  • A Privacy Dashboard. A privacy dashboard lets users periodically revisit earlier choices and decide if they want to change their minds. For example, if a consumer goes shopping at a mall out of town, they might allow its app to access their location information in order to receive offers, but now that they’re back home, there’s no reason for the app to have that information.

The FTC’s recommendations have implications for developers too. App developers are expected to know what information they are providing to third parties (such as ad networks), and furthermore what those third parties are doing with it.

Another important provision is the FTC’s recommendation of Do Not Track or DNT capability. Users should be able to tell their devices not to track them. The setting for this should be easy for users to find and work persistently across all apps. DNT should work at the platform level, but it also has implications for ad networks, which the article says “should work with platforms to ensure implementation of an effective DNT system for mobile.” Although many of the FTC’s recommendations will improve apps, it is unlikely that ad networks are going to jump right on board with DNT based solely on a recommendation.

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