
The National Telecommunications and Information Administration Thursday released a draft of a voluntary mobile app code of conduct, the result of a multistakeholder process spurred by the Obama Administrations push for an online privacy bill of rights.
The code essentially directs app developers and publishers to provide consumers with short-form notices, in multiple languages where appropriate, on how information is collected and shared by the app.
The notices, says the code, should include:
(a) the collection of [various] types of data and whether or not consumers know that it is being collected; b) a means of accessing a long form privacy policy, if any exists; c) the sharing of user-specific data, if any, with third parties listed in Section II.B as defined below; and d) the identity of the entity providing the app.
The notices need to be easy to read and understand and must include whether the app collects biometrics, browser history, phone logs, contacts, financial info, health or medical info, location information or user files.
The notice does not have to be included if the collection is incidental and actively submitted by a user through an open field, rather than being encouraged to submit that specific data.
The notice should also include whether that info is transmitted to ad networks, carriers, consumer data resellers, data analytics providers, government entities, operating systems and platforms, other apps and social networks.
The notice is not required for sharing data with third parties if there is a contract between the app and the third party that limits use of the data to provide a service to or on behalf of the app or the contract prohibits sharing the consumer data with other third parties.
Notice is not required if the data is not identified or de-identified if steps are taken to insure it cannot be re-associated with a specific individual.
The code encourages flexibility and creativity in creating the notice, so long as the font stands out and the notice is easily accessible.
CTIA: The Wireless Association did not outright endorse the code, but praised the process encouraged its members to kick the tires on the code. CTIA has been encouraged by the experience of parties working together in the multistakeholder process, it said in a statement. While member companies will need to evaluate the final Code thoroughly, CTIA supports company consideration of the draft Code of Conduct for voluntary adoption and support.
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