The FTC’s Child Apps Study: How ACT is Engaged in Promoting Transparency

Today’s survey by the FTC raised the same concerns that ACT has shared in our Congressional testimony on mobile app privacy. Many children’s education app developers are unaware of existing privacy regulations and how they may be interpreted to prevent seemingly innocuous features. ACT has traveled across the country to meet with app developer groups like Moms with Apps to explain how privacy laws apply to them and to suggest best practices for protecting child privacy online. We have found that the overwhelming majority of those making 99 cent apps for kids do so to help their own children learn and with a desire to help others learn. There is certainly a need to protect children’s privacy online and a broader education effort is necessary to inform well-meaning developers of the precautions they should take. ACT is committed to working with the FTC and our 4,000 members to expand these education efforts. We should ensure that the parents buying these apps for their children can be as confident in the safety of their privacy as are the parents who made the apps.

While this is a report on app disclosure policies, and does not examine whether any consumer information is being used, it does highlight areas for improvement that ACT has long endorsed. Primarily, app developers must strive for transparency to let users know whether and how they use their information. While many children’s app developers don’t collect information or use ads, we believe that conveying this information in an easy to read privacy policy helps consumers and assures them of the safety of their data. We also believe that while the overwhelming majority of children’s app makers are well-intentioned, if there are those who operate with malice outside the law, we fully endorse regulatory action by the FTC. As it has shown in the Playdom and Broken Thumbs Apps, the Commission is well-empowered to bring enforcement actions against transgressors large and small.