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Privacy labels---standardized, compact representations of data collection and data use practices---are often presented as a solution to the shortcomings of privacy policies. Apple introduced mandatory privacy labels for apps in its App Store in December 2020; Google introduced mandatory labels for Android apps in July 2022. iOS app privacy labels have been evaluated and critiqued in prior work. In this work, we evaluated Android Data Safety Labels and explored how differences between the two label designs impact user comprehension and label utility. We conducted a between-subjects, semi-structured interview study with 12 Android users and 12 iOS users. While some users found Android Data Safety Labels informative and helpful, other users found them too vague. Compared to iOS App Privacy Labels, Android users found the distinction between data collection groups more intuitive and found explicit inclusion of omitted data collection groups more salient. However, some users expressed skepticism regarding elided information about collected data type categories. Most users missed critical information due to not expanding the accordion interface, and they were surprised by collection practices excluded from Android's definitions. Our findings also revealed that Android users generally appreciated information about security practices included in the labels, and iOS users wanted that information added.
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PolicyChecker: Analyzing the GDPR Completeness of Mobile Apps' Privacy Policies
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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- Award ID(s):
- 2246143
- PAR ID:
- 10488760
- Publisher / Repository:
- ACM
- Date Published:
- Journal Name:
- Proceedings of the 2023 ACM SIGSAC Conference on Computer and Communications Security (CCS)
- ISBN:
- 9798400700507
- Page Range / eLocation ID:
- 3373 to 3387
- Subject(s) / Keyword(s):
- Mobile App, Privacy Policy, GDPR, Completeness
- Format(s):
- Medium: X
- Location:
- Copenhagen Denmark
- Sponsoring Org:
- National Science Foundation
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- Free Publicly Accessible Full Text
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Accepted Manuscript1.0
- Conference Paper:
- https://doi.org/10.1145/3576915.3623067
