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Google Data Safety Form is Effective July 20, 2022

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 it is imperative that they be completed in time to avoid non-compliance.

Next Steps for Organizations – Aligning Public Facing Disclosures

Legal and development teams should continue to work together to align the Data safety form and iOS nutrition labels with other public-facing disclosures, such as the organization’s privacy policy. Specifically, it is important that both the legal and development teams collaborate to understand and accurately represent how their apps are behaving. This is especially true considering the development team typically publishes the mobile app store disclosures, and the legal team drafts the privacy policy.

With NT Analyzer’s downloadable report and designated module for Android (similar to the designated iOS module for iOS apps), the dev and legal teams will have the information they need to meet their Data safety form requirements and make accurate disclosures and representations about their apps. The report includes, but is not limited to:

  • Identifying all parties collecting data (as well as which SDKs are integrated into the app);
  • Identifying all data types, including personal information/data (at both a technical – e.g., hashed, encoded, fingerprinting, GAID, etc. – and traditional level); and
  • Determining how each data type is used (e.g., App Functionality and/or Personalization).

Reach out for more information on how we can help your organization prepare for the data safety form with NT Analyzer.

 

Special thanks to law clerk Nicole Sakin for her assistance in the preparation of this content.

Steven Roosa

Author Steven Roosa

Steven B. Roosa advises companies on a wide spectrum of technology and legal issues pertaining to privacy and data security. Steve serves as partner in Norton Rose Fulbright's New York office and oversees the firm's privacy compliance tool suite, NT Analyzer.

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Steven Roosa

Author Daniel Rosenzweig

Daniel B. Rosenzweig is a lawyer in Norton Rose Fulbright's Data Protection, Privacy and Cybersecurity practice group in the New York office. Daniel is part of the core team that oversees NT Analyzer to help clients navigate the complex data protection and privacy landscape.

More posts by Daniel Rosenzweig