Thursday 16 February 2012

Children’s privacy – being disappointed with the FTC

I was quite looking forward to reading the US Federal Trade Commission’s report about the privacy aspects of mobile applications for children, which was published today.

Until I read it, that is.

And, with a heavy heart, I wondered if this was not just another golden lost opportunity to make an important point.

The report focused on the point that currently privacy disclosures are disappointing. I didn’t really want to read that. What I did want to read was why they are disappointing, in terms of the harm that had been caused to kids as a result of these disappointing privacy disclosures.

But, unfortunately the report didn’t focus on the consequence of the disappointing privacy disclosures.

If I were a legislator, I might find it hard to get all worked up about a report about non-compliance with rules, unless I could have also had been presented with evidence of the results of the non compliance – rather than just evidence of the non-compliance. Then, I could have bounded up onto my soap box with a little more vigour.

I have to be able to answer the basic question “Does it matter if you don’t comply with rules that, if ignored, don’t result in harm?”

Because if I can’t find much evidence of harm, then I’m concerned that hardly anyone’s going to be bothered to listen to me.


The report recommends:
• All members of the "kids app ecosystem" – the stores, developers and third parties providing services – should play an active role in providing key information to parents.
• App developers should provide data practices information in simple and short disclosures. They also should disclose whether the app connects with social media, and whether it contains ads. Third parties that collect data also should disclose their privacy practices.
• App stores also should take responsibility for ensuring that parents have basic information. "As gatekeepers of the app marketplace, the app stores should do more." The report notes that the stores provide architecture for sharing pricing and category data, and should be able to provide a way for developers to provide information about their data collection and sharing practices.