Privacy on the Go – California Attorney General Publishes Recommendations

Privacy on the Go was published by California’s Attorney General in January 2013. It offers the AG’s privacy practice recommendations for participants at all levels of the mobile ecosystem.

Privacy on the Go begins with a message from the AG. Part of that message explains why the publication was produced (emphasis added).

The world has gone mobile. Today, 85 percent of American adults own a cell phone and over half of them use their phones to access the Internet. The mobile app marketplace is also booming with more than 1,600 new mobile apps being introduced every day. These apps allow us to do everything from streaming movies to hailing a cab to viewing our own X-ray and ultrasound images.

Along with the many wonderful capabilities these apps offer, we remain mindful that the mobile environment also poses uncharted privacy challenges, such as the difficulty of providing consumers with meaningful information about privacy choices on small screens and the many players who may have access to sensitive user information. These are challenges that we must confront and that we must resolve in a way that appropriately protects privacy while not unduly stifling innovation.

The publication’s 27 pages include recommendations for app developers, app platform providers, mobile ad networks, operating system developers, and mobile carriers. This post focuses on Privacy on the Go recommendations for app developers.

Those recommendations fill seven pages and, thus, are too long to present in their entirety. Here is the AG’s summary of those recommendations.

• Start with a data checklist to review the personally identifiable data your app could collect and use it to make decisions on your privacy practices.
• Avoid or limit collecting personally identifiable data not needed for your app’s basic functionality.
• Develop a privacy policy that is clear, accurate, and conspicuously accessible to users and potential users.
• Use enhanced measures – “special notices” or the combination of a short privacy statement and privacy controls – to draw users’ attention to data practices that may be unexpected and to enable them to make meaningful choices.

Related posts:

• If You Want Personal Info from CA Residents, You Need a Privacy Policy
• Meaningful Privacy Policy Statements – the California Perspective

Dana H. Shultz, Attorney at Law  +1 510 547-0545  dana [at] danashultz [dot] com
This blog does not provide legal advice and does not create an attorney-client relationship. If you need legal advice, please contact a lawyer directly.