February 2014

Every software app developer needs to know about the latest software app privacy issues, so I thought I would provide a brief summary of some of the best published privacy guidelines for app developers. You may have missed it, but the Federal Trade Commission (aka FTC), the Attorney General for the State of California, and the Future of Privacy Forum and Center for Democracy & Technology (aka FPF and CDT), have each created a great privacy guideline document for app developers. This is something app developers should have on their radar screen, as if you have forgotten, messing this up can be very costly/painful, etc. (Remember the Path.com app privacy fiasco Link).

Ok, so here goes.

The FTC and the California suggestions are similar so I combined them below:

 App Developers

• • Review the collection and use of personally identifiable data
  • Create a clear Privacy Policy
  • Use Enhanced Measures (e.g. in app notices)
  • Use Just-In-Time Disclosures

App Platforms

• • Make app privacy policies accessible from the app platform
  • Use the platform to educate users on mobile privacy
  • Use Just-In-Time Disclosures
  • Use privacy icons

Mobile Ad Networks

• • Avoid out-of-app ads
  • Create a Privacy Policy
  • Move away from device identifies to temporary identifies (see Carrier IQ Situation Link)

Mobile Carriers

• • Educate mobile customers on privacy issues

 The FPF and CDT created a checklist:

 1)   Practice ‘Privacy By Design’ (this is a Canadian invention, but it has been adopted by the FTC Link)

2)   Communicate Openly & Effectively

3)   Make your Privacy …