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What Are Apple Privacy Labels and How Transparent Are They, Really?

Apple Privacy Labels Now Required on All Apps in the Apple App Store

In the past few months there has been a lot of sparring over new Apple privacy labels as they require companies that have apps in the Apple App Stores to comply with Apple’s new policy of disclosing to users what type of data they may be collecting on the user and whether that data can be linked to the user.

What Are Apple Privacy Labels? 

Since Apple rolled out these new privacy labels, many have likened Apple’s privacy label to FDA nutrition labels in that they show a user what kind of data-collecting “ingredients” are “packaged” into any particular app.  Simply put, Apple touts its “privacy labels” as an easy way for users to quickly determine what kind of data may be collected on them when they use a particular app.  In announcing this new feature, Apple stressed that privacy is a “fundamental right” and that “Apple’s ultimate goal” is transparency. 

So how does it work? Well, first of all, if an app developer wants to have their app offered for download in Apple’s App Store, they must first answer privacy questions posed by Apple before submission. Apple’s requirements include, for example, identifying all of the data that the developer and third parties collect, affirming they meet Apple’s own privacy policies, and disclosing whether the information collected can be connected to the user.

Do Apple Privacy Labels Provide True Transparency?

Interestingly, however, is the fact that Apple does not require disclosure of all data collection.  So, while this is a huge step in terms of transparency in privacy practices, it still relies heavily on self-reporting.  Therefore, while big companies like Google® are incentivized to be fully transparent with their disclosures due to the heavy scrutiny they face, smaller companies that are less known can simply choose not to disclose all of the information they collect. 

Consequently, Apple’s new privacy labels may result in some users operating under the misimpression that the app they are using does not collect a particular kind of data, when they indeed do, simply because that company chose not to disclose. Using the nutrition label comparison again, this would be like allowing a company to simply “opt out” of disclosing all the calories in a serving just because they wanted to.

Key Takeaways on Apple Privacy Labels 

Apple’s new “privacy labels” are a welcome change and have had a huge impact on privacy practices in mobile apps because:

  • they require apps offered in Apple’s App Store to disclose if they are collecting certain kinds of data;

  • they require apps to disclose if information collected can be connected to users; and

  • they show users through quick graphical representations what kind of information is being collected on them by a particular app.

For more information on data privacy legal services, Technology & Data and Industry Focused Legal Solutions pages.


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