FTC Advice On Making App Location Data More Transparent

Here are some tips on ways to explain your location-collecting practices and offer choices to consumers:

• If a consumer downloads your app through the iOS8 system, the app can’t access location when it’s not in use unless the consumer affirmatively allows it in response to a system-level prompt. The dialog box for this prompt includes space for details. That’s a good place to clearly explain why you want to access this information, how you will use it, and if you share it.
• What if your app is available through an operating system that doesn’t provide system-level disclosures and choices about this type of location collection? You can use the app itself to explain your practices and offer choices. For example, before you start collecting location data when the app isn’t in use, give users an in-app notification that explains why you want to access the information and gives them opportunity to opt in.
• Regardless of what platform consumers use to get your app, your privacy disclosures and other information pages offer another place to spell out your practices. Ditch the legalese and tech jargon. Explain in language people will understand whether you collect their location when they’re not using the app and what you use that information for.

If you access users’ locations when they’re not using your app, it’s a good idea to clearly disclose what you’re doing and provide users with choices.