Having advocated for and conducted research on short standardized privacy notices for the past two decades, I was excited when I heard Apple and Google would roll out mobile-app privacy "nutrition labels" (short-form, standardized privacy policies) in their respective app stores. However, when the first iOS labels appeared at the end of 2020, my excitement was replaced with disappointment. The iOS labels were not prominently placed, used confusing terminology, and too often seemed inconsistent with information in the apps' privacy policy. In April 2022, labels appeared in the Android app store that took a different approach from iOS yet appeared to suffer from similar problems.
I wasn't the only one disappointed. A New York Times reporter wrote that the iOS labels were, "often illuminating," but complained that they "created more confusion."2 A Washington Post reporter wrote about apps that deceptively claim on their labels that they don't collect data, when in fact they do.8 In February 2021, members of the U.S. Congress wrote to Apple CEO Tim Cook with concerns that app labels were misleading consumers.3
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