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FTC’s advice in a nutshell: start with minimum reasonable data security, then disclose, disclose, disclose, and go from there.
Because travel and its subsectors have a huge footprint in mobile, whether in transactions, booking, research or any other services, mobile app companies, larger companies and developers should be paying close attention to U.S. FTC guidelines that just came out on enhancing mobile privacy, security and disclosures for consumers. This comes as FTC fined mobile photo app Path $800,000 for violating privacy rules and threatened to come down hard on the industry in the future if it doesn’t fall in line.
So what are these guidelines? Thankfully FTC has a detailed document for it, and we’ve extracted the summary of these guidelines, from the document (full doc embedded below):
Platforms, or operating system providers offer app developers and others access
to substantial amounts of user data from mobile devices (e.g., geolocation information,
contact lists, calendar information, photos, etc.) through their application programming interfaces (APIs). In addition, the app stores they offer are the interface between users
and hundreds of thousands of apps. As a result, platforms have an important role
to play in conveying privacy information to consumers. While some platforms have
already implemented some of the recommendations below, those that have not should:
Recommendation for app platforms such as Apple, Google, Amazon, Microsoft, and Blackberry
- Provide just-in-time disclosures to consumers and obtain their affirmative express consent before allowing apps to access sensitive content like geolocation;
- Consider providing just-in-time disclosures and obtaining affirmative express consent for other content that consumers would find sensitive in many contexts such as contacts, photos, calendar entries, or the recording of audio or video content;
- Consider developing a one-stop “dashboard” approach to allow consumers to review the types of content accessed by the apps they have downloaded;
- Consider developing icons to depict the transmission of user data;
- Promote app developer best practices. For example, platforms can require developers to make privacy disclosures, reasonably enforce these requirements, and educate app developers;
- Consider providing consumers with clear disclosures about the extent to which platforms review apps prior to making them available for download in the app stores and conduct compliance checks after the apps have been placed in the app stores;
- Consider offering a Do Not Track (DNT) mechanism for smartphone users. A mobile DNT mechanism, which a majority of the Commission has endorsed, would allow consumers to choose to prevent tracking by ad networks or other third parties as they navigate among apps on their phones.
App developers should:
- Provide just-in-time disclosures and obtain affirmative express consent before collecting and sharing sensitive information (to the extent the platforms have not already provided such disclosures and obtained such consent);
- Improve coordination and communication with ad networks and other third parties, such as analytics companies, that provide services for apps so the app developers can provide accurate disclosures to consumers. For example, app developers often integrate third-party code to facilitate advertising or analytics within an app with little understanding of what information the third party is collecting and how it is being used. App developers need to better understand the software they are using through improved coordination and communication with ad networks and other third parties.
- Consider participating in self-regulatory programs, trade associations, and industry organizations, which can provide guidance on how to make uniform, short-form privacy disclosures.
Advertising networks and other third parties should:
- Communicate with app developers so that the developers can provide truthful disclosures to consumers;
- Work with platforms to ensure effective implementation of DNT for mobile.
App developer trade associations, along with academics, usability experts
and privacy researchers can:
- Develop short form disclosures for app developers;
- Promote standardized app developer privacy policies that will enable consumers to compare data practices across apps;
- Educate app developers on privacy issues