- Provide just-in-time disclosures and obtain affirmative express consent before collecting and sharing sensitive information (to the extent the platforms have not already provided such disclosures and obtained such consent);
- Improve coordination and communication with ad networks and other third parties, such as analytics companies, that provide services for apps so the app FTC Staff Report developers can provide accurate disclosures to consumers. For example, app developers often integrate third-party code to facilitate advertising or analytics within an app with little understanding of what information the third party is collecting and how it is being used. App developers need to better understand the software they are using through improved coordination and communication with ad networks and other third parties.
- Consider participating in self-regulatory programs, trade associations, and industry organizations, which can provide guidance on how to make uniform, short-form privacy disclosures.
These aren't the only two groups that the FTC noted, however. The agency also noted that advertising networks should better communicate with app developers and should work with platform developers. Additionally, app developer trade associations, academics, usability experts and researchers should come up with better short form disclosure notices, create standardized and uniform privacy policies, and better educate app developers on privacy issues.