The European General Data Protection Regulation (GDPR) mandates a data controller (e.g., an app developer) to provide all information specified in Articles (Arts.) 13 and 14 to data subjects (e.g., app users) regarding how their data are being processed and what are their rights. While some studies have started to detect the fulfillment of GDPR requirements in a privacy policy, their exploration only focused on a subset of mandatory GDPR requirements. In this paper, our goal is to explore the state of GDPR-completeness violations in mobile apps' privacy policies. To achieve our goal, we design the PolicyChecker framework by taking a rule and semantic role based approach. PolicyChecker automatically detects completeness violations in privacy policies based not only on all mandatory GDPR requirements but also on all if-applicable GDPR requirements that will become mandatory under specific conditions. Using PolicyChecker, we conduct the first large-scale GDPR-completeness violation study on 205,973 privacy policies of Android apps in the UK Google Play store. PolicyChecker identified 163,068 (79.2%) privacy policies containing data collection statements; therefore, such policies are regulated by GDPR requirements. However, the majority (99.3%) of them failed to achieve the GDPR-completeness with at least one unsatisfied requirement; 98.1% of them had at least one unsatisfied mandatory requirement, while 73.0% of them had at least one unsatisfied if-applicable requirement logic chain. We conjecture that controllers' lack of understanding of some GDPR requirements and their poor practices in composing a privacy policy can be the potential major causes behind the GDPR-completeness violations. We further discuss recommendations for app developers to improve the completeness of their apps' privacy policies to provide a more transparent personal data processing environment to users.
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GUILeak: Tracing Privacy Policy Claims on User Input Data for Android Applications
The Android mobile platform supports billions of devices across more than 190 countries around the world. This popularity coupled with user data collection by Android apps has made privacy protection a well-known challenge in the Android ecosystem. In practice, app producers provide privacy policies disclosing what information is collected and processed by the app. However, it is difficult to trace such claims to the corresponding app code to verify whether the implementation is consistent with the policy. Existing approaches for privacy policy alignment focus on information directly accessed through the Android platform (e.g., location and device ID), but are unable to handle user input, a major source of private information. In this paper, we propose a novel approach that automatically detects privacy leaks of user-entered data for a given Android app and determines whether such leakage may violate the app's privacy policy claims. For evaluation, we applied our approach to 120 popular apps from three privacy-relevant app categories: finance, health, and dating. The results show that our approach was able to detect 21 strong violations and 18 weak violations from the studied apps.
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- Award ID(s):
- 1748109
- NSF-PAR ID:
- 10065206
- Date Published:
- Journal Name:
- Proceedings - International Conference on Software Engineering
- ISSN:
- 0270-5257
- Format(s):
- Medium: X
- Sponsoring Org:
- National Science Foundation
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- Free Publicly Accessible Full Text
-
Accepted Manuscript1.0
- Conference Paper:
- https://doi.org/10.1145/3180155.3180196
