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GDPR for iOS Developers

Andrey Butov
September 11, 2018

GDPR for iOS Developers

GDPR is a complex set of regulations. It can be difficult to figure out what parts apply to your iOS app, and what you should be doing to comply with GDPR. But there's actually quite a bit of regulation in GDPR that applies to iOS apps. This talk dives into 12 of the more important items you should know when getting your iOS app prepared for GDPR.

Andrey Butov

September 11, 2018
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  1. @andrey_butov
    GDPR for iOS developers
    Andrey Butov
    [email protected]

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  2. What is GDPR?
    (General Data Protection Regulation)
    Regulation designed to give individuals
    more control over their personal data.

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  3. To whom does GDPR
    apply?

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  4. Where do I fit in?
    Data Controller
    Data Processor
    Data Subject
    Data Protection Officer
    Uses the data for business goals (app owner, etc).
    Processes the data on behalf of the controller (ad network, crash
    handler, Crashlytics, Urban Airship, Google, Bugsnag, etc.
    The app user.
    A person appointed to be explicitly in charge of all this stuff -
    probably does not apply to you unless you are processing a large
    amount of personal data and run a large operation.

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  5. Things to keep in mind.
    Written by politicians.

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  6. Things to keep in mind.
    Mainly with larger companies in mind.
    Written by politicians.

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  7. Things to keep in mind.
    Lawyers don’t have all the answers.
    Mainly with larger companies in mind.
    Written by politicians.

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  8. Things to keep in mind.
    Litigation sets precedent.
    Lawyers don’t have all the answers.
    Mainly with larger companies in mind.
    Written by politicians.

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  9. Things to keep in mind.
    Best sincere effort, while keeping
    the intent of the regulation in mind.
    Litigation sets precedent.
    Lawyers don’t have all the answers.
    Mainly with larger companies in mind.
    Written by politicians.

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  10. Personal data
    • Email address
    • IP address
    • Advertising identifier
    • GPS location
    • MAC address
    • Physical address
    • Date of birth
    • Social security number
    • Financial information

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  11. Personal data
    • Physical characteristics like eye color, weight, etc.
    • Salary and tax information.
    • Religious and political preferences.
    • Medical information.
    Why?

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  12. Anything that, by itself, or in combination
    with other pieces of data, can be used to
    identify an individual.
    Personal data

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  13. Personal data
    … which means?
    Every piece of data ever?
    Anything that, by itself, or in combination
    with other pieces of data, can be used to
    identify an individual.

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  14. If you hesitate, or feel you have to ask “is
    this personal data”, it is personal data.

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  15. If you hesitate, or feel you have to ask “is
    this personal data”, it is personal data.
    • Because we just don’t know.

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  16. If you hesitate, or feel you have to ask “is
    this personal data”, it is personal data.
    • Because until it’s resolved through litigation
    and has precedent (and even then), we just
    don’t know.
    • Because we just don’t know.

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  17. If you hesitate, or feel you have to ask “is
    this personal data”, it is personal data.
    • Because it’s safer to follow the intent of the
    regulation, be conservative, and err on the side
    of caution.
    • Because until it’s resolved through litigation
    and has precedent (and even then), we just
    don’t know.
    • Because we just don’t know.

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  18. What if you fail to comply?

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  19. What if you fail to comply?
    €20 million or 4% of annual revenue

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  20. What if you fail to comply?
    €20 million or 4% of annual revenue
    (whichever is higher)

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  21. iOS app backed by a web app?
    Your web app privacy policy should reflect what
    data is being collected and for what purpose.

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  22. Privacy by design
    You can only hold and process data that’s
    absolutely necessary for a project to be
    completed.

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  23. Privacy by design
    You can only hold and process data that’s
    absolutely necessary for a project to be
    completed.
    Data should be deleted after it’s no longer
    needed.

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  24. Privacy by design
    You can only hold and process data that’s
    absolutely necessary for a project to be
    completed.
    Data should be deleted after it’s no longer
    needed.
    If there’s a data breach, you must notify users
    within 72 hours.

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  25. Data portability
    The user (data subject) has the right to
    request his/her data from you (data
    controller), at any time.

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  26. Data portability
    You must provide for a way to transfer the
    data to another controller, if requested.
    The user (data subject) has the right to
    request his/her data from you (data
    controller), at any time.

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  27. Data portability
    You must provide that data in a commonly-
    used, machine-readable format.
    You must provide for a way to transfer the
    data to another controller, if requested.
    The user (data subject) has the right to
    request his/her data from you (data
    controller), at any time.

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  28. Data portability
    This must be done without hindrance or
    penalty to the user.
    You must provide that data in a commonly-
    used, machine-readable format.
    You must provide for a way to transfer the
    data to another controller, if requested.
    The user (data subject) has the right to
    request his/her data from you (data
    controller), at any time.

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  29. Consent

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  30. “Do I need to ask for consent if I just want to
    show ads in my app?”

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  31. “Do I need to ask for consent if I just want to
    show ads in my app?”
    Yes

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  32. “Do I need to ask for consent if I just want to
    show ads in my app?”
    “But I’m not collecting any personal data!”
    Yes

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  33. “Do I need to ask for consent if I just want to
    show ads in my app?”
    “But I’m not collecting any personal data!”
    But your ad network is, and you’re
    responsible.
    Yes

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  34. 3rd-party ad network SDKs collect the
    advertising identifier (IDFA), which is
    personally-identifiable data, and, in some
    cases, the GPS location, both of which
    require consent.

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  35. Some ad networks (Admob), let you turn
    off personalized ads.

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  36. Some ad networks (Admob), let you turn
    off personalized ads.
    Option 1:
    Ask for consent (properly). Receive consent.
    Allow Admob to collect the IDFA, and show
    personalized ads.

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  37. Some ad networks (Admob), let you turn
    off personalized ads.
    Option 1:
    Ask for consent (properly). Receive consent.
    Allow Admob to collect the IDFA, and show
    personalized ads.
    Option 2:
    Don’t ask for consent (or consent is denied,
    etc). Configure Admob to show generic ads.

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  38. What about Google’s Consent SDK?

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  39. What about Google’s Consent SDK?
    This was rushed. Google did not
    want to do this.

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  40. What about Google’s Consent SDK?
    This was rushed. Google did not
    want to do this.
    The phrasing is a bit … slimy.

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  41. What about Google’s Consent SDK?
    This was rushed. Google did not
    want to do this.
    The phrasing is a bit … slimy.
    You are still responsible. Google
    does not want to be a data
    controller.

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  42. The consent request must be prominent
    and separate from your terms and
    conditions.

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  43. You can’t stick a “you agree that we will
    collect …” paragraph inside the EULA.
    The consent request must be prominent
    and separate from your terms and
    conditions.

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  44. Your request for consent should not use
    any pre-ticked checkboxes, or any other
    pre-selected default values.

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  45. Your requests must use clear, plain
    language, that is easy for the user to
    understand.

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  46. You need to explain why you are
    collecting the data (for what purpose is it
    going to be used?)
    consentmonitor.com

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  47. Each distinct piece of
    data you collect needs
    its own consent.
    consentmonitor.com

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  48. Inform users about
    all third-parties that
    will be using the
    data.
    consentmonitor.com

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  49. You need to keep a record of when and how
    you collected consent for each piece of data,
    from each of your app users.

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  50. You need to keep a record of the exact wording
    of the request that the user gave consent to.
    consentmonitor.com

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  51. You need to inform
    users about their
    right to withdraw
    consent at any time.
    consentmonitor.com

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  52. You need to inform
    users about their
    right to withdraw
    consent at any time.
    consentmonitor.com
    You need to give
    users the ability to
    withdraw consent at
    any time.

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  53. You need to give users the
    ability to submit a request-
    to-be-forgotten.
    consentmonitor.com

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  54. consentmonitor.com

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  55. consentmonitor.com
    Properly requests consent, as required by GDPR.
    Retains a record of consent for every piece of data, for every
    user, including meta-data on how the consent was requested.
    Allows your users to easily revoke or update consent.
    Allows your users to easily submit a request-to-be-forgotten.
    Gives you a trail of evidence that consent was given by this
    exact user, for this exact piece of collected data, for this
    exact purpose.

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  56. @andrey_butov
    [email protected]
    Thank you!

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