FPF Asks NTIA to Focus on "App Privacy"

The Future of Privacy Forum (FPF) today filed its suggestion with the NTIA that a first area that the Multi-Stakeholder Process should address is mobile device applications. In February, the White House announced a privacy initiative through which enforceable industry codes of conduct would emerge from a Multi-Stakeholder Process, and it requested input from interested parties on which privacy issues should be addressed through the process.

In a submission filed with the National Telecommunications and Information Administration (NTIA), FPF observed:  “The continued proliferation and use of mobile devices by consumers for a multitude of communication and computing purposes, with a corresponding increase in downloads and use of mobile apps, makes app privacy a priority.  Reports of privacy issues with mobile apps abound, making the issue timely and urgent.”  The mobile app issue recently was addressed by FPF co-chairs Jules Polonestky and Christopher Wolf in an opinion piece recently published by the San Jose Mercury News.

FPF strongly supports the Administration’s efforts to enhance data privacy protections and promote consumer trust in a networked society.  FPF also supports NTIA’s efforts to facilitate the development of enforceable codes of conduct through a Multi-Stakeholder Process.  With the rapid evolution of technology, an approach in lieu of technology-specific and prescriptive legislation and one that allows affected parties to participate is prudent.

In proposing mobile apps as a first area of focus for the MSHP process, FPF noted the   important work that has already been done in the area and urged the integration of the foundational work already done and the continuation of parallel activities.

It noted the app best practices guidelines and model app privacy policies already have been produced by the GSMA (representing mobile operators, the Electronic Frontier Foundation (“EFF”), the Center for Democracy and Technology (“CDT”), the Future of Privacy Forum and the Mobile Marketing Association (“MMA”), which provide a substantive starting point for consideration of binding Codes of Conduct.  And it observed that further progress is expected from efforts such as the April 25, 2012 App Developer Privacy Summit convened by the Future of Privacy Forum, the Application Developers Alliance and the Stanford Center for Information and Society.

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