Nicole Sakin is an associate in Norton Rose Fulbright's Information Governance, Privacy and Cybersecurity practice group in the Washington, DC office. Nicole advises clients on compliance with data protection and privacy laws, including COPPA, GLBA, HIPAA, TCPA, VPPA, FTC Act, and CCPA/CPRA and other state privacy laws. Nicole has experience with drafting applicable disclosures, privacy policies, and operational controls, as well as advising clients on building and implementing their privacy compliance programs across all stages of the development lifecycle. She also assists clients with drafting and interpreting technology-related contracts, including insertion orders, service provider addendums, and data protection agreements/addendums.
Google’s Data safety forms must be submitted by July 20, 2022. Failure to post by July 20, 2022, according to Google, can result in the rejection of new app submissions to Google Play. After July 20,200, non-compliant apps may face removal from the Google Play altogether. It’s the business’s job to take ownership over the accuracy of the labels and…
After more than a year of negotiations, on March 25, 2022, the European Commission and the United States announced an agreement for a new Trans-Atlantic Data Privacy Framework. The new Framework will replace EU-U.S. Privacy Shield, which was invalided by the Court of Justice of the European Union (“CJEU”)’s Schrems II decision in July 2020. Since the Schrems II decision,…
Google recently announced several key changes to the upcoming “Data safety form” for Google Play, including: Required Timeline Extended to Submit Data safety form: Google extended the deadline from April 2022 to July 2022. Specifically, according to Google: July 20, 2022: All new apps and updates to existing apps must include a Data safety form. If an app fails to…
As we previously noted, iOS 15 rolled out several privacy-focused measures to users. For example, users may record their app activity and download a report on app metrics from the previous seven days, called the App Privacy Report. These metrics include, for example: 1) when apps access certain permissions on the device (e.g. microphone, location, camera, etc.) and 2) which…
Android will adopt iOS-like privacy nutrition labels, called the “Data safety form,” starting April 2022. And according to Google, apps that fail to comply with this upcoming requirement may be “subject to policy enforcement, like blocked updates or removal from Google Play.” While it may be tempting to just repurpose the iOS nutrition labels, Google notes “the Data safety form…
In April 2020, Apple rolled out the App Tracking Transparency (“ATT”) framework, prompting legal and development teams to identify apps that “track”, as defined by Apple, users or access the IDFA and implement the ATT framework accordingly. See here for the NT Analyzer blog post. Technically, if a consumer chooses to opt-out of tracking, the app should no longer “track”…