FTC Report Finds Mobile Applications for Children May Not Be Fulfilling Privacy Obligations

By Jennifer Kashatus

On February 16, the Federal Trade Commission (FTC) issued a staff report summarizing current privacy disclosures in mobile applications (mobile apps) targeted to children.  To better understand mobile apps directed to children, the FTC conducted a survey of certain apps offered for children.  FTC staff focused on types of apps offered to children, age range of intended audience, disclosures provided to users about the apps’ data collection practices, availability of interactive features, and parental controls.

After reviewing the survey results, the FTC Staff concluded that despite the large amount of data that some apps collect from and about children, the apps provide little information to children prior to downloading the applications.  The FTC Staff has now called upon the mobile app industry to provide greater transparency about its information collection practices.

FTC Staff recommends that app developers should provide information about their data collection practices to parents through short and simple disclosures that are easy to find and understand on a screen of a mobile device.  In these disclosures, the app should identify what information it collects, how that information will be used, and with whom the information will be shared.  App developers also should inform parents if the app collects with social media or allows any targeted advertising.

The FTC reminds mobile app providers that they are subject to the Children’s Online Privacy Protection Rule (COPPA) if they collect information about children under the age of 13.  Under COPPA, operators of online services, including mobile apps, must provide notice and obtain parental consent prior to collecting information from children under the age of 13.  The FTC Staff also cautioned that it actively enforces COPPA and that it will be conducting an additional review within the next six months to determine whether certain app provides are in violation of COPPA.