Sometimes it’s helpful to put the iPad down, and print out a paper copy of a report, to freely highlight and underline and scratch notes in your own handwriting. That’s what I did with the FTC Report on Mobile Apps for Kids last week, and those notes are what I’d like to share with you today.
What’s all the fuss about?
The Federal Trade Commission, a United States government organization responsible for enforcing COPPA (Children’s Online Privacy Protection Act) issued a 23 page report about the quality of information consumers have available prior to downloading an app for kids.
How did the FTC conduct the study in the report?
Staff members at the FTC typed in “kids” to the Apple and Android app stores, and collected app promotion pages for the first 480 results from each store. Out of those 480, they chose 200 at random from each store and looked at the landing pages of associated developer websites.
What were they looking for?
According to the report, “Staff also looked to see if the app linked to any social media, allowed users to make purchases (“in app purchases” or “IAP”), including advertising, displayed developer contact information, and provided information about the app’s data collection practices…as well as contact and data collection information from the developer.” (Page 4)
The FTC did not download any of the apps surveyed, they just read the available marketing information that a consumer can easily access about an app. So, their perspective was about information consumers have available prior to download.
What did they find?
Besides coming across a lot of animal and alphabet apps, they remarked on the following:
- Data Collection/Sharing: Little information about data collection or sharing practices of apps.
- IAP: Limited disclosures (aside from “Top In App Purchases”) about in app purchase mechanisms. FTC is now evaluating what types of consumer protections should apply to in app purchases.
- Social Features: “Staff believes that the presence of social features within an app is highly relevant to parents selecting apps for their children, and that such functionality should be disclosed prior to download.” (Page 14)
- Advertising: “Parents need clear, easy-to-read, and consistent disclosures regarding the advertising that their children may view on apps…” (Page 15)
What did they acknowledge?
The report acknowledges the parental controls available (such as “airplane mode”) on mobile devices which can restrict some of the aforementioned features. However, the report also noted that “a parents needs to set these limits each time the child uses an app, and taking such actions may adversely limit desirable app functionality.” (Page 17)
The report concludes that current industry practices are insufficient in providing consumers with necessary product information prior to purchase, and that the mobile app ecosystem “must do more to ensure that parents have access to clear, concise and timely information about the apps they download for their children…. Armed with such information, parents can make knowledgeable decisions about the apps they choose for their children, and embrace these technologies with more confidence.” (Page 17)
The report also states that “Over the next six months, staff will conduct an additional review to determine whether there are COPPA violations and whether enforcement is appropriate. Staff will also evaluate whether the industry is moving forward to address the disclosure issue raised in the report.” (Page 2)
So where does that leave parents and developers?
That leaves developers with an opportunity to stay a step ahead of the regulators by reviewing their marketing materials now to ensure that they are disclosing the presence of any in-app-features listed above.
That leaves parents with a heads-up that the industry is still maturing and developing best practices, and in the meantime, it’s wise to be informed before making purchasing decisions about apps.
Who stepped up?
Over the weekend, several developers were discussing the report and its consequences. Here is an icon they came up with to assist in disclosing in app features that parents may care about, upfront:
The intention is to represent, through icons and straightforward text, which features outlined in the report are present (or not) in an app. Tore of Operatio Apps, a parent app developer, designed this graphic and has made it publicly available for other developers to download and implement. It covers data collection and sharing, in app purchases, advertisements, social features, and external links.
Tore made a custom screenshot to be included in his iTunes App Description, showing this icon. You can see the implementation in the first screenshot of his iTunes listing here:
Tore also updated his iTunes App Description text to reflect his disclosures in plain text. Finally, Tore updated his website to include the disclosure icon for each app, here: http://www.operatioapps.com/multiplying-acorns-hd/.
We expect these efforts to be a work in progress, iterated over time with more feedback from industry, government and consumers.
Whether this becomes a springboard for additional conversations between government, industry, and consumers, or evolves into an industry trend, is too soon to tell. But parent app developers are an impressive bunch, because their own kids remind them everyday how important it is to make good products and market them responsibly.
Lorraine Akemann | Editor | Moms With Apps