June 24, 2021

Volume XI, Number 175

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Time to Update Your Privacy Disclosure Creation Checklists? Google Will Add to Mobile Privacy Disclosure Requirements

Google recently announced that beginning next year it will require Android mobile apps to provide privacy disclosures. These disclosures will live in a new “safety section” in Google Play. The requirements include disclosing:

  • What information the app collects and how information is used;

  • How the app protects information and if it uses encryption;

  • If information is shared and if users have a choice about sharing;

  • If users can request data deletion; and

  • If the disclosures made in the safety section have been verified by an independent third party.

App developers will need to confirm to Google that the disclosures are accurate. This announcement follows on the heels of Apple nutrition label requirement, which we reported on recently. Companies can start creating these disclosures at the end of this year, even though the deadline for providing these disclosures is not until mid-2022.

Putting it into Practice: To avoid UDAAP issues, care should be taken to accurately describe practices when completing the Google process. Companies will want to make sure the disclosures match what other privacy representations it makes. Those might be in privacy policies or elsewhere

Copyright © 2021, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume XI, Number 137
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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...

312-499-6335
Chelsea Staskiewicz Labor & Employment Attorney Sheppard Mullin San Diego, CA
Attorney, Provisionally Licensed

Chelsea Staskiewicz is an attorney in the Labor and Employment Practice Group in the firm's San Diego office. She is also a member of the Blockchain and Fintech Team.

While in law school, Chelsea was selected for the U.S. Securities and Exchange Commission’s Honors Intern Program and clerked for the Cyber Unit in the Division of Enforcement.

619-338-6579
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