'Privacy and apps' – information notice

In the context of the Master in Data Protection Officer and Privacy Matter Expert, hosted by TopLegal Academy on October 27 in Milan, we addressed a number of topics related to privacy and IT; among others, we focused on topics related to apps, digital and social networks.

During the next weeks, we will provide you a number of hints on what we discussed.

This week, we will address the main issues that one needs to consider regarding information notice referred to the processing of personal data through apps.

  1. The processing of personal data through apps requires an appropriate information notice to be made available to the data subject: information required is listed under art. 13 GDPR.
  2. The information notice must be provided before the processing is started and it is important to ensure that data subjects can access such information easily. This means that the information notice should be provided within the app store - before downloading the app (e.g. via a link to the complete information notice or through an abbreviated version of it) - , in the app and in the developer's website.
  3. FAQs should be rendered available to data subjects, so that most relevant questions may be answered.
  4. A privacy dashboard should be provided to data subjects, so that they can manage their own data and consents.
  5. If the processing is modified, the data subjects should be informed through a pop-up or a banner: sufficient time should be given to data subjects to understand implications linked to the modification of the processing.

In case the modification entails the processing of personal data based on consent, it is necessary to collect the user's consent; if not provided, the additional processing cannot be conducted.

The article has been co-authored by Fabia Cairoli

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.