Children’s Apps Lack Appropriate Disclosures

According to a recent report released by the Federal Trade Commission (FTC), disclosures are sorely lacking when it comes to children’s apps being sold in mobile app stores, such as those run by Apple or Google. In the report, the FTC found that a significant number of children’s apps continue to collect personal data and transmit that information to marketers without parents’ knowledge. Even worse, many app makers claim that they don’t advertise to kids within their apps, as they simultaneously do just that. This article takes a closer look at the FTC report in question, Mobile Apps for Kids: Disclosures Still Not Making the Grade.


Back in February 2012, the FTC issued a report on a survey of mobile apps directed at children in Apple’s App Store and Google’s Android Market, which were the two largest US app stores. The survey found that little or no information was made available to parents about the privacy practices and interactive features of the mobile apps surveyed prior to download. The report required all members of the kids’ app environment to provide greater transparency about the data practices and interactive features of apps geared towards children.

The kids’ app market is growing at an unprecedented rate. Since the FTC’s report was issued last year, the market for mobile apps has continued to increase, providing benefits and conveniences to consumers. As of January 2013, there were over 775,000 apps available in the Apple App Store, an over 40 percent increase since December 2011.

The rise in the number of apps corresponds to the number of US adults owning devices capable of running such apps. According to data from the Pew Research Center, almost nine out of ten US adults own a mobile phone and more than 40 percent of these mobile phone owners download apps to their phones. However, the study revealed that 30 percent of app users have uninstalled an app that was already on their device because they learned the app was collecting personal information the users were uncomfortable sharing.

Survey Findings

The FTC survey results reflect a disappointing reality regarding the privacy protections provided by children’s apps. The study focused on Apple and Google Play app stores and aimed to identify whether child-related apps were disclosing key information to parents prior to download. The study included 480 apps from each app store. 200 apps from each store were randomly selected for a closer review of their disclosures. All apps were also tested to determine whether they contained certain interactive features, including:

  • Advertising
  • Ability to make in-app purchases
  • Links to social media
  • Collection/transmission of information from the mobile devices

The FTC report revealed that the majority of apps reviewed were collecting or transmitting information from the mobile device. Almost 60 percent of the apps transmitted device ID to the developer, advertising network, analytics company or other third party. A small percentage of the apps that transmitted device ID also transmitted geolocation and/or phone number. Surprisingly, only 20 percent of the apps reviewed disclosed any information about the app’s privacy practices.

The study also looked at disclosures around advertising within the apps. Only nine percent of apps actually stated they contained advertising, though the actual number of apps that contained ads was much higher than during the previous FTC study, thus widening the gap between disclosures and the reality of the marketplace. In fact, the FTC found 58 percent of the aps actually contained ads (despite the nine percent disclosure), and of the 24 apps that clearly stated they did not contain advertising, ten apps had ads.

Some of these discrepancies in disclosure could violated the Children’s Online Privacy Protection Act (COPPA), and parts of the FTC Act against deceptive trade practices. However, enforcement actions alone are insufficient to materially improve the privacy of children.

According to the FTC,

“The results of the survey are disappointing. Industry appears to have made little or no progress in improving its disclosures since the first kids’ app survey was conducted, and the new survey confirms that undisclosed sharing is occurring on a frequent basis… It is clear that more needs to be done in order to provide parents with greater transparency in the mobile app marketplace.”


This article takes a look at a recent FTC report regarding privacy and mobile apps geared towards children. The report, entitled Mobile Apps for Kids: Disclosures Still Not Making the Grade, was released late 2012 as a follow-up to a similar mobile app survey conducted earlier in 2012.

CIPP Exam Preparation

In preparation for the Certified Information Privacy Professional/Information Technology (CIPP/IT), and the Certified Information Privacy Professional/US Government (CIPP/G), a privacy professional should be comfortable with topics related to this post, including:

  • Data collection and transfer – mobile services (CIPP/IT; I.C.F.ii.)
  • Children’s Online Privacy Protection Act of 2000 (CIPP/G; I.B.a.iii.)

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