In the past year, the Federal Trade Commission increased enforcement of mobile privacy policies and mobile apps, particularly those used by children as regulated by the Children’s Online Privacy Protection Act (“COPPA”). Regulators across the pond in the EU has likewise viewed mobile apps and mobile devices as posing significant privacy and data security concerns.
Responding to the need, our friends at the International Association of Privacy Professionals (“IAPP”) (Attorney Richard Santalesa is a current co-chair of the IAPP’s Stamford, CT KnowledgeNet) have released a useful free Mobile App Privacy Tool that helps mobile app developers navigate the waters of the different regulatory bodies and their associates “recommendations” and regulations. Starting with a Privacy by Design approach the tool is a clever web page with a layered tabbed approach that:
“divides the requirements in each document into nine distinct topic tabs to help you hone in on what is most relevant for your mobile work. The nine categories include data collection, data retention, notice and transparency, choice and consent, accountability and oversight, specific privacy controls, security and children’s privacy, as well as a miscellaneous category that functions as a guide-specific catch-all.”
The Mobile App Privacy Tool isn’t a replacement for fact-specific legal counsel, but is an excellent starting point for reviewing the privacy requirements your mobile app should meet and further discussing with your attorney what policies are required in turn.
