California AG Continues Focus on Mobile Privacy with New Best Practice Recommendations
On January 10, California Attorney General Kamala Harris issued a report entitled “Privacy on the Go: Recommendations for the Mobile Ecosystem.” The report consists of recommended best practices for mobile app developers and other players in the mobile industry to protect consumer privacy.
The instant report, which was released after Harris received input from stakeholders throughout the mobile industry, is meant to serve as a template by which the mobile industry can develop mobile privacy policies and practices that are consumer-friendly, but that will not stifle innovation. The report also urges the mobile industry to continue to increase transparency in its practices.
Underlying the report is the concept of what Harris refers to as “surprise minimization,” whereby all players in the mobile industry should work to implement privacy protections that ensure consumers are never surprised by data practices. Some of the specific highlights of the best practices recommended by the report are as follows:
- For app developers and mobile ad networks:
- Utilize “privacy by design” techniques by starting with a data checklist for each new app to review the personal information collected by the app and to determine what privacy protections are needed;
- Limit the collection of data not needed for an app’s basic functionality;
- For app platform providers:
- Make app privacy policies accessible from the platform so that users can review them before download; and
- Use the platform to educate consumers about mobile privacy.
- For mobile ad networks:
- Avoid using out-of-app ads that are delivered by modifying browser settings or placing icons on the mobile desktop;
- Transition away from the use of device identifiers for tracking and other purposes and instead, shift to app-specific or temporary device identifiers.
- For operating system developers:
- Develop global privacy standards (such as privacy icons that can be easily recognized by consumers) that allow users to control their data and the device features accessible to apps.
- For mobile carriers:
- Use your relationship with mobile customers to educate them about mobile privacy and in particular on children’s privacy issues.
Although the report consists solely of recommended “best practices,” given Harris’s focus on mobile privacy over the past year, mobile industry players who collect personal information from California residents should consider including relevant recommendations from the report in their apps and services.