This applies to mobile app developers, whether they work on their own, or on behalf of an organization. The mobile environment, along with the new app economy it has generated, is a rapidly evolving new frontier. As with past frontiers, it is filled with both richness and potential, but also risks. For example, while apps such as new reference tools and games are now part of our daily lives, there continue to be reports of unauthorized access to user information, including address books, photos and location data.
Mindful of these developments, the Privacy Commissioners of Canada, Alberta and British Columbia have written this guidance document to help app developers in Canada to address the unique characteristics of the mobile environment which we believe create special challenges for protecting privacy. The first challenge is that while the smart phone era brings unparalleled consumer connectivity and convenience, it also holds the potential for japanese dating app in gatineau qc surveillance japanese dating app in gatineau qc individuals.
The novel uses of device sensors in apps, such as those that permit location awareness, provide the potential to follow where we go and, when combined with data on what we do and what we think, ultimately, to create a portrait of who we are. Second, conveying meaningful information about privacy choices is not a simple exercise even in a desktop environment, and the challenge for app developers is compounded in the mobile space with a small screen and intermittent user attention.
These japanese dating app in gatineau qc characteristics clearly add to the difficulty in reaching users with the right information about their privacy rights, in a form they could understand and at the right time for them to make informed choices. A third challenge is the seeming lightning speed of the app development cycle and the potential to reach hundreds of thousands of users within a very short period of time.
Given this rapidly evolving situation, Privacy Commissioners believe that it is important to japanese dating app in gatineau qc set out how those organizations that develop and launch mobile apps are required to meet their obligations under privacy laws and to support them in doing so.
It is important to recognize the complexity of the mobile app ecosystem and the many players who potentially can access personal information, including developers, service providers, app platforms, and advertisers. All stakeholders have a role to play in protecting the privacy of app users. This guidance is targeted to app developers: it focuses on the design and development of apps and the need to keep privacy top of mind in that creative process. In the future, we may address app privacy from other perspectives.
This guidance has been prepared jointly by the Office of the Privacy Commissioner of Canada and the Offices of the Information and Privacy Commissioner of Alberta and British Columbia to draw your attention to key privacy considerations when designing and developing mobile apps. Additional sources can be found at the end of this document. They are right to do so: those mobile apps that take privacy seriously will be the ones that stand out from the crowd and gain user trust and loyalty.
Privacy can be a key competitive advantage for mobile app developers in Canada. And roughly nine out of 10 were concerned with businesses requesting too much personal information, not keeping information secure, and selling it to other organizations.
These findings demonstrate that Canadians are concerned about privacy japanese dating app in gatineau qc the mobile space. Under Canadian privacy laws, you japanese dating app in gatineau qc responsible for the personal information collected, japanese dating app in gatineau qc and disclosed japanese dating app in gatineau qc your app. At japanese dating app in gatineau qc federal level, the Personal Information Protection and Electronic Documents Act PIPEDA sets ground rules for how organizations may collect, use or disclose information about individuals in the course of commercial activities.
The law also gives individuals the right to see and ask for corrections to information an organization may have collected about them. Footnote 1. While this guidance is intended for the private sector, developers who japanese dating app in gatineau qc also be building apps for governments, public bodies or health custodians should be aware of, and able to comply with, other privacy laws across Canada. The concept of personal information generally means information about an identifiable individual.
Photographs and Internet Protocol IP addresses have been found to meet the definition in specific circumstances, and there are several other types of data collected by mobile apps that could be considered personal information.
Voice print biometrics, used for example in voice recognition apps, involve the collection of the characteristics that make an individual's voice unique. Location information can reveal user activity patterns and habits. Combining disparate bits of information, derived from multiple sources, can also lead to detailed profiles that enable individuals to be identified. The Federal Court has ruled that information will be about an identifiable individual where there is a serious possibility that an individual could be identified through the use of that information, alone or in combination with other available information.
Footnote 2 Collecting, using and disclosing personal information to improve user experience, which indirectly contributes to the commercial success of your app, could still be considered a commercial activity under the law. The unique nature of personal information flowing through mobile devices, the challenge of the small screen, and the speed of the mobile app development cycle all make for a unique environment that underscores the need for comprehensive privacy protections.
Setting good practices for managing privacy doesn't need to be complicated or difficult. Anyone, from a one-person japanese dating app in gatineau qc to a large company, can build a privacy management program.
Putting in place privacy rules for your business will help you manage risks in a timely manner, such as personal information leaking from your app. And given the potentially high number of users for your app, it will also help you to respond to requests for access to their personal information and complaints in an organized manner.
You should also ensure that all of your business arrangements and contracts are compliant with privacy laws because you are ultimately accountable. Make sure you have controls in place such as contracts to ensure that third parties process personal information in accordance with their obligations under privacy law, and make sure the japanese dating app in gatineau qc are aligned with user expectations.
Privacy laws require you to inform app users, in a clear and understandable way, what you are doing with their personal information. Transparency is also what users increasingly expect and transparent actors are rewarded with user trust and loyalty.
Various data protection authorities, governments and consumer groups around the world are paying attention to how apps handle personal information. App developers are also responding to consumer demand for transparency, by providing guidance and launching apps that give the user a window into the data that is being collected, used and disclosed from their device by other apps.
Several of these sources are listed at the end of this document. They need clear and accessible information to evaluate what you are proposing to do with their japanese dating app in gatineau qc. For example, wherever the app is being made available for download, tell potential users what personal information your app will be collecting and why, japanese dating app in gatineau qc it will be stored on the device or elsewherewho it will be shared with and why, how japanese dating app in gatineau qc you will keep it, and any other issues that will affect user privacy.
More detail on how to develop appropriate notifications is found under Sections 4 and 5 of this document, which focus on the timing of notices to users and obtaining consent on a small screen. Consider whether you need to collect personal information at all. If you do collect it, japanese dating app in gatineau qc legislation requires you to limit the collection of personal information to what is needed to carry out legitimate purposes. It is possible to imagine instances where personal information could be used for extra features in an app beyond its core function.
But a child could just as easily complete addition and subtraction problems without providing any personal information. If an app collects personal information, then privacy law requires you to justify why each piece of personal information is collected and how it is used by your app. If you cannot explain how a piece of information is related to the functioning of your app, then you probably should not be collecting it.
While it may be tempting, you should avoid collecting data because you believe it may be useful in the future. Canadian privacy laws require you to restrict your data collection to what is needed for an identified purpose that exists now and delete data that you no longer need for the original purpose for which it was collected.
You should also provide a means for users to opt out of such tracking. Apps should be designed in a way that does not require you to collect any device-unique identifiers if it is not essential to the functioning of the app. Avoid associating data across apps unless it is obvious to the user and necessary to do so. For example, if your app transmits personal information, you should not log it unless it is necessary. Japanese dating app in gatineau qc you have to log it, secure it and delete it as soon as possible.
Avoid collecting information about a user's movements and activities through the use of location and movement sensors unless it relates directly to the app and you have the user's informed consent.
Never collect sound or activate the device camera without the specific permission of the user. You should have the appropriate controls in place both on the mobile device and on the backend systems that will store the information to ensure the security of the personal information being handled.
Security safeguards should be appropriate to the sensitivity of the information. Ensure that users have a clear and easy way to refuse an update, deactivate and delete the app. You should give users the ability japanese dating app in gatineau qc delete all of the data collected about them.
In particular, when users delete an app, their data should also be deleted automatically. The challenge is japanese dating app in gatineau qc show users, in a creative and meaningful way, what is actually happening with their personal information.
Communicating with users about japanese dating app in gatineau qc in the mobile app environment is complicated by the fact that user attention in japanese dating app in gatineau qc space is intermittent and limited.
However, more is needed. Users cannot be expected to remember months later information they read when downloading an app, especially given that they may have many apps on one mobile device.
This limits the value of obtaining one-time user consent. Privacy messaging carries more weight if it is delivered at the right time. If your app takes photos or video, japanese dating app in gatineau qc sure to clearly state whether your app will tag the images with location data and allow the user to opt out of this feature at the time of taking the photo or video.
Privacy practices should be highlighted during the purchase process but also upon first use of the app. Depending on the purpose of your app, you may wish to give users control over repeated prompting to avoid notice fatigue, but the user should be able to set a period of time after which the consent should be renewed. In Canada, there is an expectation and a legal requirement that app users are to be informed of what information is being collected, used and disclosed about them, as a matter of transparency and openness, and for their consent to be meaningful.
Given the popularity of apps, you can expect increased scrutiny of the privacy practices in your industry in the years ahead — both by regulators and the market itself, driven by increasingly informed, discerning and influential consumers.
This guidance has been prepared to help you improve your privacy practices and the features of your app, as both are fundamental to helping users decide which apps they will trust and continue to use.
Following these good practices will help to reassure users that you have given the protection of their japanese dating app in gatineau qc the attention it deserves.
Office of the Privacy Commissioner of Canada. Information and Privacy Commissioner of Alberta.
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