California’s Attorney General Releases Privacy Recommendations for Mobile Apps

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California’s Attorney General released, on January 10, 2013, a lengthy set of recommended privacy practices aimed at app developers, app platform providers, mobile ad networks, operating system developers, and mobile carriers. The recommendations, entitled Privacy on the Go: Recommendations for the Mobile Ecosystem, encourage all players in the mobile marketplace to “minimize surprises to users from unexpected privacy practices” by asking for greater transparency.

The California Attorney General’s report urges app developers to consider privacy implications early in the design process and to post transparent, easy to-read privacy guidelines before a mobile app is made available for download. The report advises developers to use “special notices” like icons or pop-ups just before data is collected to alert users about how personally identifiable information is being collected and shared so that users can opt not to proceed. The report further recommends that app developers create a checklist of information to collect and then flag any possible privacy issues, limit the collection of user data that is not necessary for the app’s functionality, use encryption to handle data, and limit data retention, among other things.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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