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Missing privacy manifest file

Missing privacy manifest file

Description

A Privacy Manifest is a formal declaration that outlines the types of data an application and its third-party SDK collects from its users, the purpose behind collecting this data, and the specific APIs that are utilized for these purposes.

What is a Privacy Manifest?

In a broader sense, a Privacy Manifest can be considered a comprehensive document or file within an app's project that: Lists the types of data the app collects (e.g., location, personal identifiers, usage data). Explains the purpose behind collecting each type of data (e.g., improving user experience, providing personalized content). Details the APIs and third-party SDKs used that access or collect this data. Ensures compliance with privacy laws and platform guidelines (e.g., GDPR, CCPA, Apple’s App Store Review Guidelines).

Importance of a Privacy Manifest

  1. Regulatory Compliance: Many jurisdictions around the world have stringent data protection and privacy laws. A Privacy Manifest helps ensure that an app complies with these laws by transparently declaring its data usage practices.

  2. Platform Requirements: Apple have specific guidelines and requirements regarding privacy. A detailed Privacy Manifest helps in meeting these requirements, particularly for passing the App Store review process.

  3. User Trust: Transparency in how an app collects, uses, and manages user data can significantly enhance user trust. A Privacy Manifest is a step towards building this transparency, showing users that the app respects their privacy.

  4. Data Minimization and Purpose Limitation: By forcing developers to explicitly list and justify the data they collect, a Privacy Manifest encourages the principles of data minimization and purpose limitation. These principles are core to privacy-by-design practices, ensuring apps do not collect more data than necessary and use the data only for declared purposes.

Why You Should Add It for Privacy Reasons

  1. Enhances Transparency: It provides users with clear information on what data is collected and why, enabling them to make informed decisions about using the app.

  2. Builds User Confidence: Demonstrating a commitment to privacy can differentiate an app in a crowded marketplace, potentially increasing its appeal to privacy-conscious users.

  3. Prepares for Future Regulations: The regulatory landscape is evolving rapidly, with increasing emphasis on user privacy and data protection. Proactively adopting measures like a Privacy Manifest positions an app well for future compliance needs.

  4. Avoids Legal and Reputational Risks: Failure to comply with privacy laws and guidelines can result in significant fines, legal challenges, and damage to an app's reputation. A Privacy Manifest is a step towards mitigating these risks.

Recommendation

To address the requirement of declaring a Privacy manifest file (PrivacyInfo.xcprivacy) for your iOS app and its third-party SDKs, you need to create and configure this file to detail the types of data your app collects, the reason for collecting this data, and the specific APIs that require these declarations. This step is crucial for ensuring your app's compliance with privacy guidelines, enhancing transparency, and building trust with your users.

Here's an overview of the steps and an example to guide you in setting up the PrivacyInfo.xcprivacy file:

Step 1: Create the Privacy Manifest File

  1. Choose File > New File
  2. Scroll down to the Resource section, and select App Privacy File type.
  3. Click Next.
  4. Check your app or third-party SDK's target in the Targets list.
  5. Click Create.

Step 2: Add Entries for Required APIs

Inside your PrivacyInfo.xcprivacy file, you will need to add key-value pairs that represent the APIs your app or its third-party SDKs use, along with the reasons for their use. The keys should be the names of the APIs, and the values should be strings that describe the purpose of using these APIs in your app.

Here's an example structure of what your PrivacyInfo.xcprivacy might look like. This example assumes the use of "File timestamp APIs" and "User defaults APIs":

  <?xml version="1.0" encoding="UTF-8"?>
  <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.apple.com/DTDs/PropertyList-1.0.dtd">
  <plist version="1.0">
    <dict>
        <key>NSPrivacyAccessedAPITypes</key>
        <array>
            <dict>
                <key>NSPrivacyAccessedAPIType</key>
                <string>NSPrivacyAccessedAPICategoryDiskSpace</string>
                <key>NSPrivacyAccessedAPITypeReasons</key>
                <array>
                    <string>E174.1</string>
                </array>
            </dict>
            <dict>
                <key>NSPrivacyAccessedAPIType</key>
                <string>NSPrivacyAccessedAPICategoryUserDefaults</string>
                <key>NSPrivacyAccessedAPITypeReasons</key>
                <array>
                    <string>CA92.1</string>
                </array>
            </dict>
        </array>
    </dict>
  </plist>

Step 3: Ensure Accuracy and Compliance

Reflect App Functionality: Ensure that the reasons listed accurately reflect how your app uses the data derived from these APIs. No Tracking: Confirm that you do not use the APIs or derived data for tracking purposes unless explicitly declared and necessary for the app’s functionality. Review and Update as Needed: As your app evolves, regularly review and update your PrivacyInfo.xcprivacy file to match any new data collection or API usage.

Step 4: Documentation and Review

Before submission, double-check your app's documentation and in-app disclosures to ensure they are in alignment with the declarations made in your PrivacyInfo.xcprivacy file. This coherence is vital for passing App Store Review Guidelines, particularly those related to privacy.

Adhering to these steps will help ensure your application meets the required standards for privacy and data use transparency, facilitating a smoother review process and enhancing user trust.

Standards

  • OWASP_MASVS_L1:
    • MSTG_ARCH_12
  • OWASP_MASVS_L2:
    • MSTG_ARCH_12
  • GDPR:
    • ART_5
    • ART_25
    • ART_32
    • ART_35
  • PCI_STANDARDS:
    • REQ_2_2
    • REQ_6_2
    • REQ_6_3
    • REQ_7_3
  • OWASP_MASVS_v2_1:
    • MASVS_PRIVACY_3