Privacy for Mobile Developers
                                                   Kasey Chappelle
                                      http://www.vodafone.com/start/privacy.html

                                                     Ricardo Varela
                                              http://twitter.com/phobeo



                                                  OverTheAir 2010




image borrowed from http://xkcd.com
What is Privacy?

    The ability of individuals to know of, and to
    express choice and control over how information
    about them is collected, shared and used
Why should I care?

     
         Your users (increasingly) care
     
         The press loves a privacy story
     
         Regulators are watching
Some defnitions: Personal Information

    Data relating to an
    identifed or identifable
    individual, for example:
    ●
        collected via an
        application UI
    ●
        gathered indirectly from   
                                       To be identifed, an
        user's device                  individual doesn't need to
    ●
        gathered from user's           be called by name, their
        behaviour                      information may be
                                       associated to a unique
    ●
        generated by the user          identifer
Some defnitions: Location data

    Information that
    identifes the
    geographical location
    of a user's device,
    which may include
    GPS coordinates, cell
    id info, wif essids or
    other less granular
    data such as town or
    region
Some defnitions: Active Consent
                
                    Affrmative indication
                    of agreement by the
                    user to a specifc and
                    notifed use of their
                    personal information.
                    Must be captured in a
                    way in which consent
                    is not the default
                    option.
About Transparency, Choice and
           Control
Be transparent

    Tell your user who you are, what personal
    information your app will use and why, and who
    else you might share it with
Be transparent
A good place to put this
is in your privacy policy,
clearly linked from the
app
Be transparent
A good place to put this
is in your privacy policy,
clearly linked from the
app
Be transparent
Remember that just
teling the user WHAT you
need doesn't tell them
WHY you need it
Be transparent
Remember that just
teling the user WHAT you
need doesn't tell them
WHY you need it
No surreptitious data collection

    Before users activate the app, make them aware
    of features that might affect their privacy

    Eg: don't access/use location data without letting
    them know
No surreptitious data collection
Remember that there is some data you may have
access to even without specifc APIs or prompting
(for example, location from their IP) and inform your
user if you intend to use it too
Identify yourself

    Users must know who is using their personal
    information so they can exercise their rights to
    access, correct and delete information.

    That info can be included in the application itself
Identify yourself
Can the user easily fnd
contact information
inside the app?
Identify yourself
Can the user easily fnd
contact information
inside the app?
Minimize the info collected

    The application should collect and use only the
    info required for its normal operation and other
    legitimate uses (e.g., consent, required by law)
Minimize the info collected
Do you really need
all that information?
Gain their consent

    Sometimes (but not always) users will need to
    give active consent to use of their information:
    secondary purposes, public display, sharing with
    third parties or remote/persistent storage
Gain their consent
Will the users be aware
I'm about to do this
action with their data?
Gain their consent
Will the users be aware
I'm about to do this
action with their data?
Help them choose

    Make users aware of the privacy-related default
    settings and allow them to exercise their privacy
    choices (in an easy way)

    You can help a user decide by showing the
    consequences of the actions being proposed
Help them choose
Do users understand
what they are allowing
you to do?
Beware of the blanket
         
               Whenever you access data with a blanket
               permission (no prompts required) be sure to
               show your own prompt reminding the user that
               this is the case, at least once and until the user
               confrms they want no further reminders




image borrowed from http://www.starkeith.net/
No silent updates

    Inform the users of material changes in the way
    your application will collect their data BEFORE
    you enable the changes. If the change is
    essential for the application, give them a chance
    to disable/exit the application
No silent updates
Use whichever
mechanisms your
platform has to let users
know what has changed
No silent updates
Use whichever
mechanisms your
platform has to let users
know what has changed
Don't facilitate stalking or surveillance

    Applications should not collect, use or share data
    about someone other than the user except when
    the other party has chosen to publish that
    information
Don't facilitate stalking or surveillance
About Data Retention and Security
Tell them why

    Inform the user why you need to retain her
    personal data and for how long you need to keep
    it (and make sure it's justifable)
Tell them why
Make sure your data
management policy is
justifed
Explain them how you know so much

    Whenever you offer results based on data
    mining, try not to surprise your user by providing
    some explanation about how their data has been
    used to reach those conclusions
Explain them how you know so much
Let the users know what
part of their information
you use to minimize the
surprise
Keep it secure

    User data stored on the device or remotely must
    be stored somehow securely, for example by
    being encrypted (and ensuring the encryption
    keys are kept in a trusted environment)
Keep it secure
Ensure some form of
encryption when storing
the users' information
Delete my data if I ask you to

    Give the users a way to either delete their data
    themselves or contact you and ask you to delete
    it.
About Advertising
Not all Advertising has an impact in
                   Privacy

    When we talk Advertising here, we refer to
    Advertising that uses personal information, such
    as targeted advertising, or advertising that
    involves user data being send to a third party,
    such as embedding a third party ad tracking
    code
Let me know you have Ads

    Let users know the application will display ads
    before they activate it. Additionally you can
    mention what to do if they don't want ads (like
    getting the paid-for app)
Let me know you have Ads
Users should know
beforehand what to
expect
Let me know you have Ads
Users should know
beforehand what to
expect
rd
    Give users choices about 3 parties

    If you're using analytics or network advertisers,
    you're required by law to let users know
    (generally in a privacy policy) and tell them how to
    opt out (or get their opt in, in some countries).
rd
  Give users choice about 3 parties
Let me opt out if I don't
want to share data (and
is not essential to the
service)
Target advertisement using legitimate
                data

    Avoid targeting ads using personal information
    which hasn't been collected for the application's
    primary purpose
Respect the privacy of my network

    Don't spam your users' contacts - applications
    should not collect information about or send
    messages to contacts without the user's active
    consent
Respect the privacy of my network
Don't spam my contacts
About Children and Adolescents
Age verify where possible and
                appropriate

    If the application context requires features like
    social network access or displays restricted
    content, integrate age verifcation controls. When
    not possible, you can implement self-certifcation
    asking for a date of birth before activation of the
    application or feature.
Age verify where possible and
              appropriate
If nothing else is
available, self-verifcation
is fne
Set privacy-protective default settings

    Applications targeted at children and adolescents
    should will require careful treatment of social
    features, especially those using location.
In summary...
High Level Principles

    Be transparent – don't surprise your users with
    unexpected data uses or sharing

    Be reasonable – if you don't need data, don't
    collect it; if it's no longer needed, don't keep it

    Give your users meaningful choices about how
    their data is collected, used and shared

    Respond to your users' queries – in some cases,
    the law requires it
Thanks! :)
           Kasey Chappelle
http://www.vodafone.com/start/privacy.html


             Ricardo Varela
       http://twitter.com/phobeo

thanks to Belen Albeza (@ladybenko) for
             the cartoons!

Over The Air 2010: Privacy for Mobile Developers

  • 1.
    Privacy for MobileDevelopers Kasey Chappelle http://www.vodafone.com/start/privacy.html Ricardo Varela http://twitter.com/phobeo OverTheAir 2010 image borrowed from http://xkcd.com
  • 2.
    What is Privacy?  The ability of individuals to know of, and to express choice and control over how information about them is collected, shared and used
  • 3.
    Why should Icare?  Your users (increasingly) care  The press loves a privacy story  Regulators are watching
  • 4.
    Some defnitions: PersonalInformation  Data relating to an identifed or identifable individual, for example: ● collected via an application UI ● gathered indirectly from  To be identifed, an user's device individual doesn't need to ● gathered from user's be called by name, their behaviour information may be associated to a unique ● generated by the user identifer
  • 5.
    Some defnitions: Locationdata  Information that identifes the geographical location of a user's device, which may include GPS coordinates, cell id info, wif essids or other less granular data such as town or region
  • 6.
    Some defnitions: ActiveConsent  Affrmative indication of agreement by the user to a specifc and notifed use of their personal information. Must be captured in a way in which consent is not the default option.
  • 7.
  • 8.
    Be transparent  Tell your user who you are, what personal information your app will use and why, and who else you might share it with
  • 9.
    Be transparent A goodplace to put this is in your privacy policy, clearly linked from the app
  • 10.
    Be transparent A goodplace to put this is in your privacy policy, clearly linked from the app
  • 11.
    Be transparent Remember thatjust teling the user WHAT you need doesn't tell them WHY you need it
  • 12.
    Be transparent Remember thatjust teling the user WHAT you need doesn't tell them WHY you need it
  • 13.
    No surreptitious datacollection  Before users activate the app, make them aware of features that might affect their privacy  Eg: don't access/use location data without letting them know
  • 14.
    No surreptitious datacollection Remember that there is some data you may have access to even without specifc APIs or prompting (for example, location from their IP) and inform your user if you intend to use it too
  • 15.
    Identify yourself  Users must know who is using their personal information so they can exercise their rights to access, correct and delete information.  That info can be included in the application itself
  • 16.
    Identify yourself Can theuser easily fnd contact information inside the app?
  • 17.
    Identify yourself Can theuser easily fnd contact information inside the app?
  • 18.
    Minimize the infocollected  The application should collect and use only the info required for its normal operation and other legitimate uses (e.g., consent, required by law)
  • 19.
    Minimize the infocollected Do you really need all that information?
  • 20.
    Gain their consent  Sometimes (but not always) users will need to give active consent to use of their information: secondary purposes, public display, sharing with third parties or remote/persistent storage
  • 21.
    Gain their consent Willthe users be aware I'm about to do this action with their data?
  • 22.
    Gain their consent Willthe users be aware I'm about to do this action with their data?
  • 23.
    Help them choose  Make users aware of the privacy-related default settings and allow them to exercise their privacy choices (in an easy way)  You can help a user decide by showing the consequences of the actions being proposed
  • 24.
    Help them choose Dousers understand what they are allowing you to do?
  • 25.
    Beware of theblanket  Whenever you access data with a blanket permission (no prompts required) be sure to show your own prompt reminding the user that this is the case, at least once and until the user confrms they want no further reminders image borrowed from http://www.starkeith.net/
  • 26.
    No silent updates  Inform the users of material changes in the way your application will collect their data BEFORE you enable the changes. If the change is essential for the application, give them a chance to disable/exit the application
  • 27.
    No silent updates Usewhichever mechanisms your platform has to let users know what has changed
  • 28.
    No silent updates Usewhichever mechanisms your platform has to let users know what has changed
  • 29.
    Don't facilitate stalkingor surveillance  Applications should not collect, use or share data about someone other than the user except when the other party has chosen to publish that information
  • 30.
  • 31.
  • 32.
    Tell them why  Inform the user why you need to retain her personal data and for how long you need to keep it (and make sure it's justifable)
  • 33.
    Tell them why Makesure your data management policy is justifed
  • 34.
    Explain them howyou know so much  Whenever you offer results based on data mining, try not to surprise your user by providing some explanation about how their data has been used to reach those conclusions
  • 35.
    Explain them howyou know so much Let the users know what part of their information you use to minimize the surprise
  • 36.
    Keep it secure  User data stored on the device or remotely must be stored somehow securely, for example by being encrypted (and ensuring the encryption keys are kept in a trusted environment)
  • 37.
    Keep it secure Ensuresome form of encryption when storing the users' information
  • 38.
    Delete my dataif I ask you to  Give the users a way to either delete their data themselves or contact you and ask you to delete it.
  • 39.
  • 40.
    Not all Advertisinghas an impact in Privacy  When we talk Advertising here, we refer to Advertising that uses personal information, such as targeted advertising, or advertising that involves user data being send to a third party, such as embedding a third party ad tracking code
  • 41.
    Let me knowyou have Ads  Let users know the application will display ads before they activate it. Additionally you can mention what to do if they don't want ads (like getting the paid-for app)
  • 42.
    Let me knowyou have Ads Users should know beforehand what to expect
  • 43.
    Let me knowyou have Ads Users should know beforehand what to expect
  • 44.
    rd Give users choices about 3 parties  If you're using analytics or network advertisers, you're required by law to let users know (generally in a privacy policy) and tell them how to opt out (or get their opt in, in some countries).
  • 45.
    rd Giveusers choice about 3 parties Let me opt out if I don't want to share data (and is not essential to the service)
  • 46.
    Target advertisement usinglegitimate data  Avoid targeting ads using personal information which hasn't been collected for the application's primary purpose
  • 47.
    Respect the privacyof my network  Don't spam your users' contacts - applications should not collect information about or send messages to contacts without the user's active consent
  • 48.
    Respect the privacyof my network Don't spam my contacts
  • 49.
    About Children andAdolescents
  • 50.
    Age verify wherepossible and appropriate  If the application context requires features like social network access or displays restricted content, integrate age verifcation controls. When not possible, you can implement self-certifcation asking for a date of birth before activation of the application or feature.
  • 51.
    Age verify wherepossible and appropriate If nothing else is available, self-verifcation is fne
  • 52.
    Set privacy-protective defaultsettings  Applications targeted at children and adolescents should will require careful treatment of social features, especially those using location.
  • 53.
  • 54.
    High Level Principles  Be transparent – don't surprise your users with unexpected data uses or sharing  Be reasonable – if you don't need data, don't collect it; if it's no longer needed, don't keep it  Give your users meaningful choices about how their data is collected, used and shared  Respond to your users' queries – in some cases, the law requires it
  • 55.
    Thanks! :) Kasey Chappelle http://www.vodafone.com/start/privacy.html Ricardo Varela http://twitter.com/phobeo thanks to Belen Albeza (@ladybenko) for the cartoons!