Privacy by Design and Best Practice Guide on Mobile App Development
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1 Mobile App Development Forum on Privacy and Security The Office of the Privacy Commissioner for Personal Data, Hong Kong 21 April 2016 Privacy by Design and Best Practice Guide on Mobile App Development Henry Chang, Chief Personal Data Officer Office of the Privacy Commissioner for Personal Data, Hong Kong
2 Privacy by Design and Best Practice Guide on Mobile App Development Basic principles of data protection Case studies on the good and the bad Best practice guide for mobile app development 1
3 Developing Mobile Apps with Privacy Protection in Mind Basic principles of data protection 2
4 Data Flow and Data Protection Principles (DPPs) Collection Personal Data Flow Storage, Use or Processing Retention/ Erasure IT System DPP 1 Collection DPP 3 Use DPP 2 Accuracy and retention DPP 4 Security DPP 5 Transparency DPP 6 Rights of access and correction 3
5 Privacy by Design Privacy by Design* is the philosophy of embedding privacy from the outset into the design specifications of accountable business processes, physical spaces, infrastructure and information technologies * 4
6 The Essence of Privacy by Design A clever person solves problem, a wise person avoids it. Data Minimisation! 5
7 Privacy by Design When Applying to App Development 1. Is the access of the information necessary? a) If access is necessary, has it been explained in the collection statement/privacy policy? b) If access is necessary, is the uploading of the information necessary? c) If uploading is necessary, is the storage necessary? d) If access is necessary, is the sharing/transferal of the information necessary? 2. What other information is being collected/combined/associated? 3. What safeguards (such as validation, proper encryption and access controls) are in place to the information accessed/transmitted/shared/kept? 4. Is the retention policy reasonable and can app users opt-out of any of these collections and erase/delete collected information and accounts? 5. Do you have a set of process and procedures to fulfil the data access and correction obligation? 6
8 Technical Considerations (To be covered by PISA and HKCERT) Use reliable software development tools (SDKs; libraries) Understand what access third-party tools (such as those from Flurry) will have to mobile device data Use most granular/specific/least privileged calls you can Remember Confidentiality, Integrity and Accountability Be familiar with mobile-specific vulnerabilities/hacking techniques Perform code-review and software testing 7
9 Case studies on the good and the bad The good, the bad and the ugly 8
10 Examples The good 9
11 The Good - Transparent Available before installation (Nearly) single page and in simple language Specific to the types of data accessed Assured users what it would not do But don t copy this 10
12 The Good - Build Your Own Granular Controls For iphone: Why not port the logic to Android? 11
13 Examples and the ugly 12
14 Mistake or Don t Care? 13
15 Over-collection or Don t Care? 14
16 Best Practice Guide for Mobile App Development PCPD Website -> Resources Centre -> Publications -> Guidance Notes 15
17 Best Practice Guide for Mobile App Development: Modular and flow-chart approach 16
18 Best Practice Guide for Mobile App Development: Legal requirements 17
19 Best Practice Guide for Mobile App Development: Privacy by Design explained 18
20 Best Practice Guide for Mobile App Development: Best practice recommendations 19
21 Best Practice Guide for Mobile App Development: Checklist for self-evaluation 20
22 Best Practice Guide for Mobile App Development: Transparency 21
23 Your App Could be Here Next Year as a Good Example 22
24 What Next More practice sharing: PISA How to properly implement encryption? HKCERT How to manage security in mobile apps? PolyU How to do a black-box check? 23
25 Privacy by Design and Best Practice Guide on Mobile App Development 24
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