On October 17, in furtherance of their continued support for self-regulation of online behavioral advertising, the Mobile Marketing Association released the MMA Mobile Application Privacy Policy for public comment.  The policy is intended to spark self-regulation of privacy and data processing of mobile applications.  The policy was created with the input of a committee of market leaders, including AT&T AdWorks, Microsoft, Procter & Gamble, Sprint-Nextel, The Nielsen Company, Verizon Wireless, and Yahoo!.

The privacy policy seeks to provide mobile app developers with language that can be quickly and completely understood by a mobile app user., although it makes no mention of how it should best be displayed on a small screen.  To that end, the policy serves as a model or starting point for most mobile application developers and is annotated to provide guidance to those considering implementing a privacy policy.  While the policy is designed to address core privacy issues and data processes of most mobile applications, the MMA encourages those who plan to implement the policy to consult an attorney or data privacy specialist to ensure that it is tailored to each application or company.

The policy prods mobile application developers to clearly explain how user information is collected, used and retained, and what third parties have access to information obtained by mobile apps.  For example, the policy spells out the difference in how information is obtained, such as what information is user provided and what information is automatically collected.  In addition, the policy covers whether the application collects the precise real time location information of the device, such as for check-in services.  Mobile application developers are encouraged to disclose whether third parties see or have access to information obtained by the application, and how automatically collected data is used for ad targeting.  Finally, the policy addresses opt out rights, data retention, rights of children, and security procedures.

The MMA policy serves as a way for the marketing industry to address the fact that “more than 58% of U.S. mobile users worried that their data can be easily accessed by others,” said Alan Chapell, Co-chair of the MMA Privacy & Advocacy Committee.  Establishing a privacy policy helps “establish and maintain consumer trust.”

Members of the marketing industry are encouraged to read the proposed policy and submit comments on the MMA website through November 18, 2011.   

Authorship Credit: Jennifer D. Johnson