[co-author: Dhara Shah*]
An app’s store listing will automatically update with the data safety information in February 2022. If an app has not submitted this information yet or it has been rejected, users will see “no information available.” By April 2022 all apps must have this data safety section approved. In the data safety form, apps will have to state what data the app collects. Developers will also have to note activities involving data “sharing.” The form also asks about measures taken to protect data. Apps will need to note if there are user rights, such as deletion. Developers are ultimately responsible for the accuracy of the information disclosed in this form.
There are a number of FAQs available as companies work through completing this form. For example, the FAQs note that the form should reflect the global representation of data practices. Thus, those companies that have different practices by geography will have to share version-specific information in the “about this app” section. The launch of the form is on track from Google’s initial announcement, which we reported on. Companies that fail to timely comply with this requirement may be subject to blocked updates or removal from Google Play.
*Dhara Shah is a law clerk in Sheppard Mullin’s Chicago office.