This morning, the FTC released a Staff Report titled, “Mobile Apps for Kids: Current Privacy Disclosures are Disappointing.” The report presents the results of a survey conducted by the FTC of mobile apps offered for children in the Android Market and Apple App Store. The survey focused on the following:
- Types of apps available for children;
- Age range of intended audience for each app;
- Disclosures provided to users about data collection and sharing practices;
- Availability of interactive features (e.g., connecting with social media); and
- App store ratings and parental controls for each app.
To identify apps for the survey, the staff searched each of the app stores for the term “kids,” and then reviewed the app promotion pages for the first 480 apps returned by each search. The staff then conducted a more detailed review of the promotion pages for 200 Android and 200 Apple apps randomly selected from the 480 apps examined in the first review. The survey revealed that in most cases, there was little or no information about the developer’s data collection and use practices available on either the app store promotion page or the app developer’s website.
The survey methodology did not include tests to see whether the apps actually collected, used, or disclosed personal information from children. However, the report states that the FTC plans to “conduct an additional review to determine whether there are COPPA violations and whether enforcement is appropriate” over the next six months. Accordingly, mobile app developers promoting apps for kids (or whose apps may be implicated by the FTC’s review) should review their data collection and use practices and ensure their privacy disclosures and practices are COPPA-compliant.
In the report, the FTC also made the following recommendations:
- App developers should inform parents about the information collected, how it’s used, and with whom it’s shared via “simple and short disclosures or icons that are easy to find and understand on the small screen of a mobile device;”
- App stores should: (i) provide developers with a way to consistently display information about their data collection practices; and (2) enforce existing requirements for developers to disclose their data collection and use practices; and
- Third parties collecting user information through apps should disclose their privacy practices through a on the app promotion page, developers’ disclosures, “or another easily accessible method.
The FTC also stated that it plans to host a public workshop this year to get input from interested parties about several topics, including mobile privacy disclosures, as part of its efforts to update its “Dot Com Disclosures” guidance for businesses.
