Archive for the ‘Other Privacy Authorities’ Category

22 Sep 2016

How fit is your gadget? Putting web-connected health/wellness devices through their privacy paces


Smart TVs . . . Fitness trackers . . . Automated thermostats . . . Self-driving cars . . .

The Internet of Things is the next frontier in digital technology which is why the Global Privacy Enforcement Network focused its 2016 Privacy Sweep on this emerging market. Sweep participants were especially interested in how companies communicate their personal information handling practices.

Given the sensitivity of the information that health and wellness devices, as well as their associated apps and websites, are capable of collecting, the Office of the Privacy Commissioner of Canada (OPC) focused its Sweep on 21 devices ranging from smart scales, blood pressure monitors and fitness trackers, to sleep and heart rate monitors, a smart breathalyzer and a web-connected fitness shirt.

The choice of devices dovetails with one of our four strategic privacy priorities—the body as information. Identified as an important area of focus during a priority-setting exercise that culminated in May 2015, the body as information refers to the mounting privacy concerns related to highly sensitive health, genetic and biometric information that is being used by organizations and governments in all sorts of new ways.

During the Sweep, our Sweepers—aka OPC staff—put the products to use to see first-hand what information the devices requested, compared to what privacy communications said would be collected. In some cases, they followed up with specific privacy questions for the companies.

Below is a brief assessment of how the devices stacked up.

Read the rest of this entry »


19 Sep 2016

Children’s Privacy Sweep yields positive changes


So whatever happened with that Children’s Privacy Sweep, you ask?

Before we delve into the results of the 2016 Internet of Things Sweep—look out for them very soon—we thought we should update you on the outcome of our discussions with developers behind the mobile applications (apps) and websites we raised concerns about in a blog post and/or letters issued last fall.

Read the rest of this entry »


2 Sep 2015

Who did it better? A look at children’s apps/websites and the privacy protective controls on offer


Children are more connected than ever and often miles ahead of their parents when it comes to navigating the Internet and mobile applications (apps).

They’re also among our most vulnerable demographic groups and, in their quest to access their favourite game or social network, they may be apt to give out personal information without any thought to the potential privacy ramifications.

For this reason, the Global Privacy Enforcement Network made Children’s Privacy the theme of its 3rd annual Privacy Sweep.

The Office of the Privacy Commissioner of Canada, along with 28 other privacy enforcement authorities across the country and around the globe, assessed the privacy communications and practices of some 1,494 websites and mobile apps.

The goal: to find out which of them collect personal information, what type of personal information they collect, whether protective controls exist to limit the collection and whether a simple means to delete account information exists.

By briefly interacting with the websites and apps, the exercise was meant to recreate the consumer experience – in this case, the experience of children under the age of 12. Our sweepers, which included a number of adult volunteers as well as nine children, ultimately sought to assess privacy controls based on four key indicators:

  1. Collection of children’s data: Does the app/website collect children’s personal information and if so, what information is collected? (Ex. Name, email, date of birth, address, phone number, photo/video/audio.) Does a privacy policy or other privacy communications exist and if so, does it clearly explain the app/website’s personal information handling practices?
  2. Protective controls: Do protective controls exist and do they effectively limit the collection of personal data? (Ex. Prompts for parental involvement, warnings when leaving the site, pre-made avatars/usernames, moderated chats/message boards to prevent inadvertent sharing of personal information.) Are privacy communications tailored to children? (Ex. Simple language, large print, audio, animation.)
  3. Means to delete account information: Is there a simple means for deleting account information?
  4. Overall concerns about a child using the app/website: Overall, would I be comfortable with a child using this app/website?

In total, our Office examined 172 websites and mobile apps for both Android and iOS platforms. We focused on websites and apps that are targeted at or popular among children 12 and under.

Some 118 websites and apps appeared to be targeted directly at children, while 54 were considered popular among them. In other words, while designed for older audiences or audiences of all ages, children are said to be frequent users of these apps and websites.

The bulk of websites and apps swept were based in Canada and the United States. Our Sweep included a significant number of games and educational websites and apps, as well as leisure websites and apps hosted, for example, by museums or zoos. Traditional and social media apps and websites rounded out the list.

Before delving in, let’s be clear on a few points: Since apps and websites are constantly evolving, it’s best to think about our results as a snapshot in time. Also note that the Sweep was not a formal investigation. We did not seek to conclusively identify compliance issues or possible violations of privacy legislation. This was not an assessment of an app or website’s overall privacy practices, nor was it meant to provide an in-depth analysis of the design and development of the apps or websites examined.

Instead, we have compared and contrasted some of the web/app features and privacy practices that we found to be particularly kid-friendly, with those we felt could benefit from some “child-proofing.” We learned a lot and hope these concrete examples will help Canadians, as well as website and app developers, better understand our conclusions.

The moderated message/chat function:

Moderated message/chat functions ensure contributions are vetted before they are posted publicly. Items may be vetted for content but also for personal information as free-text portals can open the door to the inadvertent sharing of potentially sensitive details.

Family.ca, a site clearly targeted at children, indicated its message board feature was moderated. Our Sweepers put that claim to the test by attempting to post a message that included a full name, age and hometown. A day later, here’s the modified message that went public:

Family.ca image. Moderated message/chat function works effectively. Message was changed to exclude personal information.

As you can see, the site even cropped the username to “victorg.” Nice catch Family.ca.

We attempted the same experiment with Lego.com. As you can see, the moderator informed us that it had rejected our post for privacy reasons. Awesome moderating decision master-builder Emmet!

Lego.com image.

Kudos to Family.ca and Lego.com which have shown how a little moderation can go a long way!

By contrast, Moviestar Planet is an example of a social networking app targeted specifically at kids that displays little self-control. While the app said it is moderated for content, children were free to post selfies with titles asking, for example, others to rate them “hot or not.” Not the sort of thing you might necessarily want out there on the Internet when you grow up. We won’t display those images to protect the privacy of the children, but you can also see how our sweeper was able to include a whole lot of personal information in the free-text chat function. Big no no! What’s stopping kids from entering their address, school or where they plan to be that afternoon?

Moviestar Planet image.

Meanwhile, sweepers noticed that websites/apps that are popular among children may moderate for certain content but not to ensure that children aren’t sharing personal details about themselves online. The website for FIFA, soccer’s governing body and a site popular with soccer fans of all ages, for instance, moderates its site to ensure that there are no violations of the Terms of Service. But as you can see below, our sweeper was able to state his age and location. Therefore this reference to moderation has more to do with the appropriateness of the content . . . You know how partisan soccer fans can get!

FIFA image.

The website’s Terms of Service also states that it is the responsibility of parents to supervise their children’s activities on the site and that appears to be as far as FIFA’s obligation goes towards moderating the content that children may be sharing. Certainly parents have a role to play in protecting children’s privacy while online, but seriously FIFA, you are not absolved from getting in the game. If you’re already moderating for content, why not make sure kids aren’t oversharing too? This serious foul deserves a red card.

Less is more:

Leave a little mystery! Profile displays do not have to give everything away.

GamezHero.com is an example of a targeted website that allows users to display a significant amount of personal information on their user profile including name, grade, gender, age and city. While the website said it does not collect from children under 13, it had no problem posting our 10-year-old’s information. Fortunately, there was no option to load a photo!

GamezHero.com image.

A similar interface on Family.ca, however, had limited options for sharing personal information. The photo was a preset graphic and messages were fixed text. In other words, kids could choose what to say from a list of phrases.

Family.ca (Less is More) image.

Things can get a little trickier with popular apps and websites. Even though many children use these sites, they are often not designed with the under 12 crowd in mind. Gurl.com is one such example. As you can see, the social platform geared at teen girls collected and posted our 10-year-old sweeper’s full name, date of birth, occupation and location.

There were also no warnings or mechanisms to prevent users from uploading photos or posting personal information on message boards, some of which broach some pretty sensitive topics such as depression, suicide and self-mutilation. Given the lack of protective controls, there’s no telling what children could post and who might see it, raising all sorts of questions about the potential for harm to one’s reputation and well-being.

Gurl.com image.

For an otherwise pretty kid-friendly website, we found this next example worth mentioning. Santasvillage.ca offered kids an easy way to “get on Santa’s nice list” – by coughing up their full name and email address. In exchange, it promised to bombard subscribers with marketing materials. Not cool Santa, we’ll take the coal.

Santasvillage.ca image.

Avatars:

Selecting an image that will serve as your online identity doesn’t have to be personal. PBSkids.org is an example of a targeted website that asked our sweeper to choose from a pre-set list of icons.

PBS.org image.

Other websites/apps asked sweepers to load their own avatar which opens the door to using personal photographs. For example, the Cookie Monster Challenge app prompted us to take a selfie for our profiles. The app’s generic privacy policy also suggested personal information may be shared with third parties.

As the Cookie Monster himself might say: Parents not like when Cookie gobble up sensitive personal information like photograph and share with udder monsters.

Cookie Monster Challenge image 1.  Cookie Monster Challenge image 2.

All in a name:

Just as children should be discouraged from using a personal photo online, so too should they be discouraged from using their real name.

Websites such as Harry Potter fan site, Pottermore.com, don’t give kids the option. Instead, our sweepers were encouraged to select a username from a pre-set list. Thanks for thinking about the privacy of your younger Hogwarts classmates, Harry!

Pottermore.com (All in a name) image.

Meanwhile, Classdojo.com, a classroom management site that connects teachers, students and their parents, got a gold star for advising sweepers in simple, child-friendly language not to use their real name. But unfortunately that gold star got yanked as there was no actual mechanism to prevent us from using it.

Classdojo.com image.

Parental control:

On the subject of parental control, there are some effective ways to limit the functionality of a website or app to protect privacy. A great way to do that is with a parental dashboard and here are a few examples that put parents in the privacy driver’s seat.

The first was Grimm’s Red Riding Hood, an app targeted at children that allowed parents to turn certain settings on and off, such as in app purchases and access to the store.

Grimm's Red Riding Hood image.

Another example is Battle.net, a popular game website designed for children over the age of 13, even though younger children are known to frequent it. As long as young users have provided a valid parental email address, parents can control settings through a fairly comprehensive dashboard.

Battle.net image shows parental dashboard to control privacy settings and voice chat.

On social networking site GeckoLife.com, parents of young children must register an account, to which they can add a child.

GeckoLife.com image shows request message sent to parents when child asks to open an account.

Parents could also monitor their child’s activities, including media uploads and connections with other users, however, the website collected a fair bit of personal information in the process.

GeckoLife.com image shows parental dashboard to set permissions to upload media and contact other users. Also asks for child`s full name,  sex and date of birth.

Now just as the First Year kids at Hogwarts require parental permission for weekend trips to Hogsmeade, young Pottermore.com users need parental permission to activate their account. Of course that means deploying a summoning charm: Accio parental email address. Good job on involving mum and dad!

But this website didn’t just seek mum or dad’s email address, it also asked for the child’s first name, country, date of birth and which Harry Potter books and movies you’ve read or watched before sending the parental consent link via email. Is all that information really necessary, Harry?

Pottermore.com (Parental Control) image.

The American Girl doll website had options to collect personal information through quizzes and sweepstakes, but to post a photo of your child with their favourite doll, parents had to provide a signed waiver.

American Girl image 1.

American Girl image 2.

These other apps clearly targeted directly at children have found some creative ways to keep wee ones out of adult sections of the site, though they do so assuming young users can’t read or follow very basic instructions! Consider making it a little tougher. Don’t forget, some wee ones are learning how to swipe a tablet screen before they can walk!

Parental control says area is for grown-ups only and asks user to enter three numbers.

Parental control says area is for grownups and asks user to swipe left with two fingers anywhere on the screen.

Delete:

What seems so simple is often anything but. To put it mildly, not all delete functions are equal. From “no brainer” to “not an option,” here’s a look at our sliding scale when it comes to ease of deleting.

For some apps/websites, it was as easy as the click of a button. Take Quizlet.com for example. This educational website allows users to sign up and join study groups on a variety of topics. But when you’re done, you simply had to click the settings button in the top right corner, scroll down and hit delete.

Quizlet.com image.

Others required a multistep process that could involve emails and/or phone calls to the company. Buried in the middle of its privacy policy is the delete option for targeted game app Despicable Me: Minion Rush.

Despicable Me: Minion Rush image 1.

Stardoll.com, a website targeted at children that allows them to create dolls and interact with other users, requires parents/guardians to fill out a form. As you might be wondering from reading this excerpt from its privacy policy, it’s not clear whether the company actually destroys the personal information it has collected or whether it simply stops collecting, using and disclosing it to third parties. Given the amount of information this site collects and displays – country, gender, date of birth and anything through its free-text function – this raised some serious concerns for sweepers.

Stardoll.com image.

Unfortunately many popular websites and apps that collect personal information had no apparent means for deleting account data, leading our sweepers to believe that their information would be out there in the ether in perpetuity.

Off course:

It’s no surprise that kids like to click on shiny colourful things which many apps and websites have in spades. What’s not cool is when those shiny colourful things lead kids to places with different personal information collection practices or questionable content.

Redirection off-site often occurs through an ad or contest icon that sometimes appears to be part of the original site.

About a third of apps did not redirect users. Bravo! Meanwhile, 14 percent of them, including Barbie.com, at least provided a pop-up warning.

Barbie.com image.

Others had more questionable redirection practices. For instance some websites/apps, including ones targeted directly at children, had ads for alcohol or dating websites that could lead users astray if clicked on. Some even had non-descript icons that, if clicked on, led sweepers to other sites that contained graphic and violent videos. Scary!

BONUS: Battle of the bands

Pop idols Justin Bieber, Taylor Swift and One Direction are all hugely popular among the under 12 crowd. But which fan site best bears that in mind when it comes to protecting the privacy of their youngest Beliebers, Swifties and Directioners?

Based on our indicators, here’s how these musical magnates stacked up.

Taylorswift.com collected username, email, full name, photo, date of birth, city, gender and occupation. There was also an unmoderated free-text function in which users could type in whatever they like. The site could display your username, photo and city. While the site attempted to block users under the age of 13, the measure could be easily circumvented by keying in a different date of birth. It also redirected visitors to a half dozen social media sites, the Google Play Store and another Taylor Swift shop that separately collects a whole host of personal information. Finally, according to the website’s privacy policy, users could “access, update or delete” personal information via email. It also noted this could be done via the “my account” area of the website. That would be great. Too bad we couldn’t actually find a delete button.

Justinbiebermusic.com could collect a fan’s first name, email, date of birth, postal code and country. It too barred users under 13 but that measure could be similarly circumvented. The site also had links redirecting users to a variety of music and social media sites, including the pop star’s Facebook fan page. To “correct, update, amend, delete/remove” personal information, users are asked to send a letter via snail mail to an address in California, or to fill out an online form. It said users could also do it through the member information page, but no such page could be found.

Onedirectionmusic.com, meanwhile, did not collect any personal information directly on site, though users could be redirected to a number of social media and music sites. The One Direction store, however, did collect a variety of personal information.

We are certainly not trying to create any “Bad Blood,” despite Taylor Swift’s lyrics, but it seems as though all three sites could use some helicopter parenting! That said, according to our final indicator, OPC sweepers said they were most comfortable with the One Direction site which seemed to hit the higher privacy notes of the three. Too bad the band has broken up:( Or so we think!

While we recognize that age verification can be tough as crafty kids have found clever ways around such mechanisms, we commend One Direction for simply limiting collection. Remember, don’t collect if you don’t have to. We also observed other sites that recognized a user’s URL and barred them from going back to the site and simply entering a different age for a period of time in order to gain access to the site. Others automatically redirected young users to a children’s version of the site. While many protective controls are seldom fool proof, we encourage developers to be creative and to find new ways of using technology to protect our most vulnerable.

Final thoughts . . .

As you can see, sweepers here at the Office of the Privacy Commissioner of Canada found many great examples of websites and mobiles apps that do not collect personal information whatsoever. We believe there are many effective ways to at least limit collection.

When it comes to protecting the privacy of children online, everybody has a role to play. Children themselves need to be educated about digital privacy issues and the perils of sharing personal information online. Teachers and parents can help instill this knowledge and should themselves be aware of what sites and apps their kids are using and what types of information they are being asked to hand over. Finally, developers should be mindful of who their users are and limit, if not eliminate, the collection of personal information from children through the use of innovative privacy protective controls.

Once we’ve finished sorting through our results, in conjunction with our provincial and international partners who are doing the same, we will determine any appropriate follow-up action.

As with last year’s Sweep, our follow-up activities could include reaching out to organizations to inform them of our findings and making suggestions for improvements. We also have the option to pursue enforcement action.

By the way, we wrote to the companies mentioned in the blog before posting this to share our concerns. Past experience has shown that education and outreach alone can often go a long way towards effecting positive change for privacy.

 


2 Sep 2015

Child sweepers share observations on web/mobile app privacy


Commissioner Daniel Therrien visits with children during Kids Privacy Sweep.

Privacy Commissioner of Canada Daniel Therrien pops in on Global Privacy Enforcement Network Children’s Privacy Sweep where a few kids are on hand to help.

A children’s privacy sweep with no children? In the words of cartoon curmudgeon Charlie Brown, “good grief!”

. . . and that was roughly genesis of the Office of the Privacy Commissioner of Canada’s (OPC) first ever Kid’s Sweep.

Nine youngsters, the offspring of OPC employees who also participated in the Sweep, descended on 30 rue Victoria one early May morning during International Sweep Week.

Fuelled on promises of pizza and cookies, the seven to 13-year-old boys and girls parked themselves in front of the laptop or tablet of their choice. Their job? To interact with their favorite apps and websites, thus recreating the user experience under the watchful gaze of their parents who took notes on how they navigated the privacy settings, or lack thereof, as the case happened to be for some sites.

The following is an edited transcript of what the kids, and their parents, had to say during a post-Sweep debrief before the smell of hot cheese and pepperoni wafted into the room and snatched their attention.

Did you have fun?

“Yeaaah!” (Kids shout in unison.)

Was anything hard or frustrating?

“It was hard to read privacy policies; they were really long and boring.”

Was it hard to sign up for some of the websites?

“If you are under 13, you are redirected to (the kid’s version of the website.)” Mom proceeded to explain that her son nonetheless managed to find a work-around.

What were some of the personal questions the website or app asked you?

“Where do you go to school? What’s your address?”

“It asked if you’re a student or a teacher.”

“It asked what gender you were.”

“Date of birth.”

“(On one website), if you typed in your real name, it wouldn’t take it or any short form of the name.”

“My photo.” (Mom added: “I wouldn’t let him. I shut it down real fast.”)

“It asked for what grade you were in.”

“(One website) asked for your picture but we just used a picture of a penguin that was already saved on the computer.” (Mom added: “But then it encouraged you to use a real picture.”)

Boy at computer.Did you always understand what the website or app was asking for?

“When I was working on (one website), I thought there were games made by other people that you could play but it was just shopping. That’s where there was the long and boring parts.”

Did any websites or apps tell you to go get a parent to help you?

“Before you were able to get on (one website), they send an email to your parent.” Mom added: “And the parent had to confirm.”

“On one website there’s a privacy mode so if you’re under 13, you can’t change it. If you want to change your age, you have to ask a parent by email.”

Did you ever click on something that led you to a totally different website?

“I was on (one website) and there was this little thing on the top of the page that said ‘are you a boy or a girl.’ It didn’t really look like an ad but it was just like a little thing with a picture and so, of course, we clicked on it and it went to another game website and it showed you a trailer.” Mom added that it was “teen rated” and included a warning that the content contained “violence, blood, partial nudity and alcohol.”

If you had to sign up for an account, did the website or app make it easy to delete your account when you were done?

“I was on (one website) and there was an option to delete the account and it deleted right away.”

Did anybody have trouble?

“A little bit. You had to email the company to delete it.”

– – – – –

Days after the Kids Sweep we got some great feedback from one of our parental sweepers who quipped that her kids are now tattling on each other for failing to read privacy policies. She added:

“They had a really good time and learned a lot about thinking critically when it comes to their personal information. If the result is that they make one brighter choice about their own privacy, then it was 100 percent worth it to me.”

It was this very comment that inspired one of our post-Sweep follow-up activities. The OPC has drafted a classroom activity for Grade 7 and 8 teachers across Canada based on our 2015 Kids Sweep.

We’ve simplified the Sweep form used to assess the privacy communications of apps and websites and are encouraging teachers to conduct privacy sweeps with students using the forms as a way to kick off a discussion about online privacy and the protection of personal information.

Alone or in groups, we are encouraging students to “sweep” their favorite apps and websites, to learn how to read privacy policies, to learn about tracking, the different types of personal information that might be collected and to discuss their observations with their teacher and peers. We’ve also provided a take-home tip sheet dubbed Pro Tips for Kids: Protecting Your Privacy for students and their parents.
Mother and daughter at computer.

Note to teachers: you can find the classroom activity on our website. As for parents and guardians, if it’s not something your kids are learning in school, think about adapting the lesson plan as a rainy Sunday afternoon activity!

Intimate, controversial or embarrassing photos and comments can have a lasting impact on a person’s reputation. Today, digital literacy as is as important as learning your ABCs and kids who understand and implement safe online privacy practices are less likely to make the sort of mistakes that could haunt them in the future.

Click here for more on the results of this year’s Children’s Privacy Sweep.


9 Sep 2014

From APP-laudable to dis-APP-ointing, global mobile app privacy sweep yields mixed results


Back in May, the Global Privacy Enforcement Network (GPEN) embarked upon its second annual Privacy Sweep, this time with a focus on mobile apps.

The Office of the Privacy Commissioner of Canada coordinated 25 other privacy enforcement authorities across the country and around the globe, in an assessment of the privacy communications of some 1,211 apps designed for both tablets and smartphones in a bid to find out which of them left our sweepers most at ease in terms of how their personal information was being collected and used.

By downloading and briefly interacting with the apps, this exercise was meant to recreate the consumer experience. Our sweepers ultimately sought to assess transparency based on five key indicators:

  1. Prior to installation, did the app explain how it would collect, use and disclose personal data via a privacy policy, app marketplace description or through some other communications tool?
  2. Which permissions did the app request access to and did the app explain why? For example, did it seek permission to access your identity/accounts, (which may include email address, Twitter handle and Facebook username, but not the information stored in those accounts); location, (based on nearby cell towers, GPS or nearby WiFi networks); photos/media/files, (which can include music, movies and other files stored on your device); camera/microphone, (which could allow the app to turn on and capture data from the phone’s camera and/or microphone, hopefully with the user’s knowledge and consent); device ID/call information (including phone number and an indication of when the user is on the phone and with whom, a request often made by games that wish to pause when the phone is engaged); and device/app history, (often used to perform diagnostics after a crash but that can include sensitive information like log data, web bookmarks and history, which apps are running on the device and other system information.)
  3. Did the sweeper feel that the permissions being sought went beyond what they expected based on the app’s functionality?
  4. Were the app’s privacy communications tailored to be read on a small screen?
  5. Overall, how satisfied was the sweeper with the privacy communications? How well did the app explain the permissions and how it collects, uses and discloses the associated personal information?

At the end of the day, users can only provide meaningful consent to the collection of their personal information if they are well informed as to how that information will be used.

In total, our Office examined 151 apps, for both Android and iOS platforms, that are popular among Canadians. About three-quarters of them were free, while the remaining ones were paid apps. Our assessment included a significant number of games, as well as health and fitness apps, news and magazine apps, and social networking apps.

We believe it’s important to share specific results from our Sweep, as we did last year, so Canadians can better understand our conclusions.

But before we start, let’s be clear: The Sweep was not intended to conclusively identify compliance issues or possible violations of privacy legislation. It was also not meant to be an assessment of the apps’ privacy practices in general, nor was it meant to provide an in-depth analysis of the design and development of the apps examined.

We haven’t conducted a formal investigation and we’ve chosen the following play on words to give you a general sense of how our sweepers felt about the apps during the experience.

With that, here are some examples of apps with the most APP-laudable, L-APP-luster and Dis-APP-ointing privacy features.

 

APP-LAUDABLE

On a scale of 0 to 3, our sweepers gave 28 per cent of apps top marks for providing timely, clear, concise explanations of their privacy practices.

In general, these apps made their privacy policies available on their website, their marketplace listing and within the apps themselves. The policies were, for the most part, consistent throughout and clearly explained how the apps would collect, use and disclose personal information.

Among the positive examples identified:

Shazam

This free app ranked 5th among music app downloads in Canada according to the popular Distimo Apple Store app chart the month of our sweep. Shazam will listen to a song or television show playing in the background and identify what it is you’re listening to or watching.

The app requests a number of permissions, including access to identity (accounts), location, photos/media/files, camera/microphone and device ID/call information.

Our sweepers were singing the praises of this app because its privacy communications provided clear explanations of individual permissions that left them with a generally positive feeling about how their personal information would be used.

For iOS, the app uses just-in-time notifications prior to accessing information, like in the example below which outlines why the app needs access to the microphone. On the Android marketplace listing, sweepers noted there’s a handy link that explains why the app needs to collect certain information. It’s appropriately dubbed: “Why does Shazam need these app permissions?”

Shazam on iOS

Shazam on Android permissions explained

Shazam on Android permissions breakdown

 

Fertility Friend: Ovulation Calendar

This free, made-in-Canada app was downloaded as many as 1 million times by Android users alone. It allows users to input cycle-related information to help track their fertility.

Sweepers were particularly pleased that this app explained not only what it would do with the information it collected, but also what it would NOT do.

For example, the app acknowledges that the type of information it collects is “extremely sensitive,” and promises not to “sell or transmit to others any personally identifiable data” entered on the site. A separate link explains that the site charges for premium services to avoid having to rely on advertisers for revenue.

Sweepers also noted the app’s privacy policy was well formatted for the small screen.

Fertility Friend on Android

As you can see from this colour-coded screen that displays menstrual cycle, fertile days and intercourse, users are required to input some pretty intimate details. These excerpts from the privacy policy, however, are quite clear about what the app will not do with that information and why.

Fertility Friend on Android

Fertility Friend privacy policy

Trip Advisor: City Guides

This popular free travel app has been downloaded more than 1 million times by Android users alone. It creates travel itineraries and offers reviews of restaurants, attractions and hotels in various cities.

Sweepers noted that the app did not provide a link to its privacy policy on either platform’s app marketplace. The policy was, however, available prior to installation on Trip Advisor’s website and in-app on Android and iOS.

The app ultimately earned APP-lause from our sweep team for tailoring its privacy communications to the app and to the small screen. The privacy policy is in an easy-to-read font and is well-structured, with a table of contents comprised of a list of explanations that users can click on to obtain more information (see the Android screenshot below for a list of hyper-linked privacy policy topics). The policy also provides a separate explanation for information collected by Trip Advisor apps on a mobile device (see iOS screenshot below).

TripAdvisor on Android

TripAdvisor on iOS

Our sweepers also gave a shout out to Trip Advisor last year when they examined the company’s website, and found its privacy policy went the extra step by offering users a detailed explanation of its “Instant Personalization” feature. The feature uses information provided by Facebook to give the user a more customized experience. The company’s explanation not only detailed what information was collected and how it was being used, but also provided instructions on how to enable and disable the feature.

L-APP-LUSTER

A significant number of apps earned praise from our sweepers for some of their privacy communications, but missed the mark in other areas.

Among them:

Trials Frontier

This free app ranked 14th overall in Canada the month before our sweep, according to Distimo’s Apple Store app chart. It’s a motorcycle racing game that allows users to compete against friends and strangers around the world.

This app makes its privacy policy available on the Google Play marketplace but not on Apple’s App Store. Also, it’s tough to locate the privacy policy on the developer’s website for iOS. Initially, users are directed to a page of game ads.

For the most part, sweepers felt the app did explain how it would collect, use and disclose personal information. The policy is fairly detailed and organized under useful headings like “what personal information does (the company) collect,” “how will my personal information be used and by whom,” and “what safeguards does (the company) use to protect my personal information.”

But this racing app earned some unwanted demerit points for failing to tailor to the small screen. On the iOS platform shown below, the privacy policy strained sweepers’ eyes, and when they zoomed in, they were forced to scroll horizontally, as well as vertically, which is cumbersome and not particularly user friendly.

Ubisoft privacy policy on Android

Ubisoft privacy policy on iOS

Guess the Emoji

This free app reached No. 48 overall in Canada the month before our sweep, according to Distimo’s Apple Store app chart.  It’s a fill-in-the-blank word game.

According to sweepers, the app seeks permission to access identity (accounts), photos/media/files and device ID/call information, among other things. The app’s privacy policy expanded on this to say that the company “may gain access to some personal data through third-parties or affiliates,” including access to “financial information such as credit card or bank account numbers and “information related to your current living accommodations.” Sweepers wondered what exactly this could mean.

The policy also provided a laundry list of potential uses of personal information, but sweepers were still perplexed as to why the app needed all those details for such purposes.

Their discomfort was only exacerbated by the policy’s explanation of the wide-ranging circumstances pursuant to which such information might be disclosed. It said, for example, that the company “may sell or rent your personal information to third parties for marketing purposes without your explicit consent.”

While it is good that the company provided a detailed explanation of the information it may collect and how it may be disclosed, privacy practices need to be justified, not just stated.

Guess the Emoji screenshot 1

See for yourself what this app proposes to do with the personal information it collects in these two screen grabs of the developer’s privacy policy.

Guess the Emoji Screenshot 2

DIS-APP-OINTING

Approximately 26 per cent of apps left our sweepers with a real sense of discomfort in terms of how they conveyed their privacy practices and, in some cases, with respect to what they said they might do with the personal information collected.

Among them:

Super-Bright LED Flashlight

This free app made it to No. 17 overall in Canada on Distimo’s top Google Play Store app chart the very week of our sweep. It allows users to turn their mobile phone into a flashlight.

The app sought permission to access the user’s camera/microphone, device ID/ call information and even photos/media/files. Besides the camera flash function, it was not made clear to sweepers why the app would need all that information to operate a flashlight.

Sweepers found no link to a privacy policy in the app’s Google Play marketplace listing so they followed a link to the “developer’s website,” which led them to a “domain parking” service. The website contained no content, except for two links, one of which was for individuals who may be interested in buying that website’s domain name – i.e. the point of domain parking. The other link took users to the privacy policy of the domain parking company, which contained nothing about the flashlight app’s collection, use and disclosure of personal information.

Without a clear and accessible policy outlining how their personal information would be used, this flashlight app left our sweepers in the dark!

 

Super-Bright LED Flashlight on Android

This image taken from an Android device shows the large number of permissions sought by this flashlight app.

Pixel Gun 3D

This free app reached No. 18 among game downloads in Canada on Distimo’s top Apple Store chart the month before our sweep. It is a multiplayer, pixel cartoon shooting game that allows users to create and customize their own characters.

This app seeks permission to access device ID/call information, device/app history and photos/media/files, among other things, but there is no privacy policy available on this app’s marketplace listing, on its website or within the app itself.

While there is no privacy policy, a “terms of use” policy available in-app, speaks to granting the developer full control over user content. This includes the ability to “sublicense and assign to third parties and a right to copy, reproduce, fix, adapt, modify, improve, translate, reformat, create derivative works from, manufacture, introduce into circulation, commercialize, publish, distribute, sell, license, sublicense, transfer, rent, lease . . . your user content . . . in connection with our provision of the game, including marketing and promotions . . .” It adds that the license granting the company this unlimited access to user content will only end once the user deletes their content or uninstalls the game, unless it’s been shared with a third party that has not deleted the information. Furthermore, the policy notes that the content “may persist in back-up copies for a reasonable period of time.”

Not only did sweepers find the terms of use policy long and legalistic, an oft-cited complaint during last year’s sweep that’s particularly challenging on the small-screen, they also found it very difficult to read as it was written in a tiny white font over a colourful, moving, animated background and required significant scrolling.

Sweepers ultimately felt the app’s privacy communications left much to be desired and, given the potentially personal nature of the permissions, they were uncomfortable using the app.

 Pixel Gun 3D on iOS

It’s best to think of our sweep as a snapshot in time. Apps are constantly evolving. While our sweepers assessed and reassessed each app over these last few months in the interest of quality control, each examination either raised new questions or answered old ones.

At the end of this experiment, one thing is clear to our sweepers: privacy communications are fluid and the level of accessibility will depend on user know-how, the platform being used (e.g. Android, iOS or BlackBerry) and the type of device, whether it’s a Lenovo tablet, an iPad or a Samsung Galaxy smartphone.

Nevertheless, we wanted to provide you with some concrete examples of what we found during our sweep.

Once we’ve finished sorting through our results, in conjunction with our provincial and international partners who are doing the same, we will determine any appropriate follow-up action.

As with last year’s sweep, our follow-up activities will include reaching out to organizations to inform them of our findings and making suggestions for improvements. We also have the option to pursue enforcement action.

Full disclosure: we wrote to the companies mentioned in the blog a week before posting to share our concerns. So far Random Logic Games/Conversion LLC, the maker of Guess the Emoji, has committed to making positive changes.

 


8 May 2013

Be prepared for a crisis with our Privacy Emergency Kit


It’s Emergency Preparedness Week in Canada – time to encourage Canadians to become better prepared to face an emergency with basic steps such as keeping bottled water and canned goods in the basement.

The Office of the Privacy Commissioner of Canada is also encouraging organizations to ensure they are prepared to address privacy issues that may arise during a time of crisis.

Personal information can play an important role in an emergency situation.  Uncertainty around the sharing of personal information could result in unnecessary confusion and delays – and have significant consequences for people.

Our Office, in consultation with several provincial and territorial counterparts, has created a Privacy Emergency Kit to help both private and public sector organizations ensure they are prepared.

Privacy laws do allow for appropriate sharing during a time of crisis, but it is crucial that organizations understand the legislation that applies to them and consider privacy issues in advance of an emergency situation.

The Government of Canada’s Get Prepared site advises individual Canadians: “Whatever you do, don’t wait for a disaster to happen.”

That’s also good advice for organizations subject to privacy legislation.


29 Apr 2013

Grappling with the impact technology is having on privacy


This week is Privacy Awareness Week (PAW) – a global effort, coordinated by members of the Asia Pacific Privacy Authorities (APPA), to raise awareness about the value of privacy and the importance of protecting it.

For PAW 2013, APPA created an infographic that illustrates how technology has changed the way we communicate, do business and store information, and how this has introduced new privacy risks as a result.

It is an issue that many are thinking about. According to OPC’s recent survey, Canadians are increasingly anxious about their privacy in the face of new technology, and 70 per cent of them feel they have less protection of their personal information than they did 10 years ago. The research also indicates that Canadians avoid downloading apps or using certain websites and services due to privacy concerns.

What can we do?

It is true that consumers expect protections when they use products and services, but it is important to also realize that consumers have an important role to play and need to take an active approach when it comes to protecting their personal information. The best thing anyone can do, when using technology to collect or store personal information, is to understand the privacy risks that come with that technology. And here are some resources to help with that task:

Mobile App: We use our mobile devices to store a goldmine of personal information. To learn more about how to protect the personal information on your mobile device, download the OPC’s free myPRIVACYapp.

Video: Privacy and Social Networks: Do you know what happens to your personal information once you post it on to social networking sites? Watch this video that OPC created to understand how social networking sites make money off of your personal information. It may cause you to ask yourself some tough questions the next time you update your information online.

Infographic: 10 tips for preventing identity theft: Anyone who has personal information is at risk of identity theft, and the risks are higher now that we use technology for so many purposes. And while it’s impossible to entirely eliminate the risk of becoming a victim, it is possible to reduce it. The OPC’s infographic details 10 things you can do to prevent yourself from becoming a target.

Introduction to Cloud Computing: When you store your photos online instead of on your home computer, or use webmail or a social networking site, you are using a “cloud computing” service. The OPC’s fact sheet explains the privacy implications of this.

For more information on the privacy risks that come with technology, and on how to protect yourself, visit the OPC’s page of fact sheets covering a range of issues and topics.


30 Apr 2012

Privacy Awareness Week 2012: Privacy Resources for Young People


Young people today are sophisticated users of the Internet, using this medium with ease and enthusiasm. It is important that they understand the impact that these technologies can have on their privacy, and that they have the tools and information they need to make smart decisions.

That’s why the Asia Pacific Privacy Authorities (APPA) forum, which includes the Office of the Privacy Commissioner of Canada, has made Privacy Resources for Young People the theme of Privacy Awareness Week 2012, April 29 – May 5.

Since 2008 our Office has been developing a variety of tools designed to teach young people about the relevance and importance of privacy when using modern technologies. The OPC has a Privacy Awareness Week 2012 web page with links to all of our privacy resources for youth, parents and educators, as well as links to privacy resources for youth developed by members of the APPA forum, at: www.priv.gc.ca/resource/paw/2012/index_e.asp.

If you would like more information on youth privacy, or to stay informed regarding our tips and tools for parents, educators and youth, visit the Office’s youth website at: www.youthprivacy.ca/.

You can also visit http://www.privacyawarenessweek.org for links to a wide variety of international privacy guidance including tips, animations, brochures, discussion topics and interactive website materials.

We also encourage you to follow us on twitter: @privacyprivee, Privacy Awareness Week: #2012PAW.


26 Jan 2012

Is your child savvy online? Check out our 12 quick privacy tips for parents.


It can be tough raising kids in a digital environment. Many of them use the Internet effortlessly, and easily adapt to new devices that connect to it. For many of us, these tools have become a routine part of our children’s lives, as they use them to chat, surf, post, play and learn. The Internet has become one of the most powerful tools they have to connect with friends and make new ones.

Many kids, however, don’t fully understand the impact that some online activities may have on their privacy. The Office of the Privacy Commissioner of Canada has come up with a new tip sheet that offers 12 practical tips for parents interested in discussing online privacy with their kids. The tips include simple ideas and advice that parents may use to limit risks to their child’s personal information, while allowing them to continue enjoying their time online.

Here is a quick list of the tips. Look at the tip sheet for detailed information on each tip!

  1. Talk to your kids.
  2. Try it out.
  3. Keep up with the technology.
  4. Make restricting privacy settings a habit.
  5. Make password protection a priority.
  6. Emphasize the importance of protecting mobile devices.
  7. Remind your kids that what they post on the Internet is not always private.
  8. Teach your kids to think before they click.
  9. Stress the importance of knowing your real friends.
  10. Teach your kids that their personal information is valuable.
  11. Let your kids know that you are there if they make a privacy mistake.
  12. Set a good example.

These tips were launched this week as part of our Office’s week-long campaign leading up to Data Privacy Day. For more information on the Office’s Data Privacy Day activities and resources, go to www.priv.gc.ca.

For more information on talking to your kids about how their use of technology can affect privacy, visit www.youthprivacy.ca/en/teachers.html.


24 Jan 2012

New Tips and Tools to Help Your Young Internet Users Protect Their Privacy Online


We all know how savvy kids are with the Internet and online tools. Many of them are way ahead of adults in adapting to new technologies, making it difficult to keep up with them – let alone educate them on online privacy.

The Office of the Privacy Commissioner of Canada is here to help. Today, we launched a new video, tip sheet and presentation package  for youth in grades 7 and 8 (Secondary I and II in Quebec) that will help parents and teachers talk to youth about the importance of protecting their privacy online.

The new video speaks to teens and ‘tweens alike, and covers the key privacy concepts kids need to consider when sharing information online. The video may be viewed online or downloaded to support discussion.

The new tip sheet offers 12 practical tips for parents interested in discussing online privacy with their kids. The tips include simple ideas and advice that parents may use to limit risks to their children’s personal information, while allowing them to continue enjoying their time online.

The Grades 7 and 8 presentation package is the latest release in the Office’s Protecting Your Online Rep presentation series. The package includes slides, speaking notes and discussion topics for use by educators and community leaders to speak with young people about online privacy. The new presentation offers much of the practical privacy advice found in the presentation package for grades 9 to 12, which our Office launched last fall, only the graphics and speaking notes have been tailored to the social realities and online activities of younger students.

These tools are being launched this week as part of our Office’s week-long campaign leading up to Data Privacy Day. For more information on the Office’s Data Privacy Day activities and resources, go to http://www.priv.gc.ca/resource/dpd/2012/index_e.cfm.