In discussing the newest voluntary short-form privacy code of conduct...

data an app does not collect, during a Thursday meeting facilitated by NTIA. Apps don’t want to list data elements that they don’t collect, said Venable lawyer and Interactive Advertising Bureau Privacy Counsel Stu Ingis. “Even just listing it may put them in a light they don’t want to be put in.” ACLU Legislative Counsel Chris Calabrese, one of the code’s drafters, said listing all of the data elements and indicating whether an app collects each would allow consumers to more easily compare the data collection and sharing practices of each app. Rather than comparing apps to one another, a consumer can compare an app’s data collection and sharing practices to what he thinks the app should be collecting and sharing, said Rob Sherman, Facebook manager-privacy and public policy. Facebook has found, through its own short-form notice experiences, that users either skip over or become confused by large amounts of information in short-form notices, he said. “We spent a lot of time thinking about the right way to provide that notice,” he said. Stakeholders also debated when apps should present users with the short-form notices. The newest draft directs apps to “make a good faith effort to provide consumers with access to the short notice prior to download or purchase of the app.” This may be technically difficult, Ingis said. “I don’t know if the platforms would allow this right now.” Michelle De Mooy, Consumer Action senior associate-national priorities, said the good-faith effort requirement could be met by including a link to the short-form notices through the app platform. No stakeholders objected to the newest draft’s language on apps that offer their short-form notices in multiple languages. The new draft reads: “Some app developers may elect to offer short form notice in multiple languages."