January 27, 2021

Volume XI, Number 27

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Apple Privacy Nutrition Labels Effective Starting Next Month

Apple has launched, in connection with other privacy changes in iOS 14, a requirement for privacy “nutrition labels.” The labels are required for new and existing apps, and are in addition to the existing requirement of linking to the company’s long-form privacy policy. Apple will automatically generate the label based on the company’s answers to its online questionnaire. Apple is requiring companies to explain what information they -and third-party partners collect. Answers will be turned into visuals for the label (a circle “i” for example, for contact information). Companies can also include optional disclosures, like confirming that data is not being used for tracking or third-party advertising purposes (if that is accurate).

Care should be taken that the person completing the questionnaire has accurate information about the company’s practices. Apple stresses that companies are responsible for the accuracy of the information provided to it. We will be watching the launch of this program to see what perspective regulators take about these labels, and potential unfair and deceptive trade practice exposure if they are inaccurate. Responses can be updated at any time.

Putting it Into Practice: Companies that operate mobile apps will need to address these App Store requirements. Care should be taken that the answers submitted into the questionnaire are accurate. To address potential UDAAP exposure, companies will want to track and update their “label” for accuracy just as companies do for their privacy policies.

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Copyright © 2020, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume X, Number 335
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About this Author

Liisa Thomas, Sheppard Mullin Law Firm, Chicago, Cybersecurity Law Attorney
Partner

Liisa Thomas, a partner based in the firm’s Chicago and London offices, is Co-Chair of the Privacy and Cybersecurity Practice. Her clients rely on her ability to create clarity in a sea of confusing legal requirements and describe her as “extremely responsive, while providing thoughtful legal analysis combined with real world practical advice.” Liisa is the author of the definitive treatise on data breach, Thomas on Data Breach: A Practical Guide to Handling Worldwide Data Breach Notification, which has been described as “a no-nonsense roadmap for in-house and...

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