The iOS SDK and Apple's Privacy Nutrition Label
Apple iOS 14 will require mobile app developers to provide their end users a privacy-based "nutrition label" about what information their app may collect and how that data is linked or possibly used to track their activity.
It is recommended that OneTrust customers prepare this information about their mobile app's privacy uses, their organization's intended purposes, and any integrated third-party vendors. The tables below outline how OneTrust SDKs are prepared to meet Apple's iOS 14 newest privacy standards for mobile apps:
Mobile app developers using the Apple App Store are required to submit this information by the December 8, 2020 deadline. For more information, see Apple's Developer site.
About OneTrust SDK Offerings
Each SDK product for the iOS platform (Native, Web, Preferences) has the ability to:
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Send user consent data to OneTrust servers when configured by the customer.
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Link the user consent data to a anonymous OR customer-provided identifier.
Using Consent Logging & User Profiles
OneTrust SDKs save user consent only on the device by default. However, if a customer wants to log consent to OneTrust servers, they can do so by enabling the Consent Logging setting in Geolocation Rules. This functionality is completely optional.
When Consent Logging is enabled, the OneTrust SDKs, by default, will generate a consent receipt using an anonymous identifier and a user's consent will be recorded against that anonymous identifier each time a user updates their consent choices. However, if a customer wants to record a consent receipt using a known identifier, the SDK supports that as well, but this is completely optional. Depending on the implementation, a known identifier could be classified as personal data if the customer decides to use something such as: Email, Phone Number, Name, Device Id, etc.
When Consent Logging is enabled, the OneTrust SDKs can also support the creation / update of a User Profile each time a user updates their consent choices on the device. A User Profile can store both consent data and custom data elements to enrich the profile. This functionality is completely optional.
To create and manage User Profiles in OneTrust, a customer will need to take the following actions with the SDK:
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Provide an identifier to the SDK to create and link a User Profile.
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Enable the Should Create Profile SDK setting which will create and update the User Profile anytime a user's consent changes.
Types of Data
|
Contact |
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|---|---|
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Name / Surname |
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically collected by the SDK. However, an application can provide this information as the identifier for creating a User Profile in OneTrust. |
|
Email Address (hashed or not) |
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically collected by the SDK. However, an application can provide this information as the identifier for creating a User Profile in OneTrust. |
|
Phone Number |
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically collected by the SDK. However, an application can provide this information as the identifier for creating a User Profile in OneTrust. |
|
Physical Address |
N/A |
|
Other |
N/A |
|
User Content |
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|---|---|
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Emails or Text Messages |
N/A |
|
Photos / Videos |
N/A |
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Audio Data |
N/A |
|
Gameplay Content |
N/A |
|
Customer Support |
N/A |
|
Other |
N/A |
|
Financial |
|
|---|---|
|
Payment Information |
N/A |
|
Credit Information |
N/A |
|
Other |
N/A |
|
Location |
|
|---|---|
|
Precise Location |
N/A |
|
Coarse Location |
The SDK auto-computes the country and region code of the user via IP Address lookup. This is done so the SDK can deliver a CMP experience tailored for the user's jurisdiction. The SDK does not use any of the device's GPS location tracking services. By default, the SDK does not send or store any location information on OneTrust servers. However, if a customer chooses to enable the Advanced Analytics feature in Geolocation Rules, the SDK will add the user's Country code to the Consent Receipt. |
|
Health & Fitness |
|
|---|---|
|
Health |
N/A |
|
Fitness |
N/A |
|
Identifiers |
|
|---|---|
|
User ID |
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically collected by the SDK. However, an application can provide this information as the identifier for creating a User Profile in OneTrust. |
|
Device ID |
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically collected by the SDK. However, an application can provide this information as the identifier for creating a User Profile in OneTrust. |
|
Usage Data |
|
|---|---|
|
Product Interaction |
When the Consent Logging feature is enabled by the application, then the SDK will collect the user's consent choices and store those choices on OneTrust servers. This consent can be tied to a anonymous OR known identifier, depending on the setting. |
|
Advertising Data |
N/A |
|
Other |
N/A |
|
Diagnostics |
|
|---|---|
|
Crash Data |
N/A |
|
Performance Data |
N/A |
|
Other |
N/A |
|
Purchase History |
|---|
|
N/A |
|
Sensitive Data |
|---|
|
N/A |
|
Contacts |
|---|
|
N/A |
|
Browsing History / Search History |
|---|
|
N/A |
|
Other Types Not Mentioned |
|---|
|
User Preference is recorded and the transaction is stored in OneTrust servers. |
Data Linked to Users
|
Privacy Protections |
YES / NO |
Notes |
|---|---|---|
|
Stripping data of any direct identifiers, such as user ID or name, before collection? |
|
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically linked back to a user's identity unless the application provides a known identifier for that user. |
|
Is the lineage broken, is re-linkage prevented to real-world identities? |
|
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically linked back to a user's identity unless the application provides a known identifier for that user. |
|
Does it link back data to users' identity? |
|
This is situational based on the implementation of OneTrust SDK, but NO by default. The value is not automatically linked back to a user's identity unless the application provides a known identifier for that user. |
|
Is data tied to other data sets that enable linking to a particular user's identity? |
|
Tracking
|
Types of Tracking |
YES / NO |
Notes |
|---|---|---|
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Are targeted ads displayed based on user data collected from other apps and websites? |
|
|
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Is device location shared with data brokers? |
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|
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Are emails, advertising IDs or other IDs shared with a third-party advertising network? |
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|
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Are third-party SDKs placed in our app? |
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Do third-party SDKs combine user data from the OneTrust app with data obtained from other developers' apps to target advertising or measure advertising efficiency? |
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|
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Is data linked solely on the end users' device and not sent off the device in a way that can identify the end user? |
|
This is situational based on the implementation of OneTrust SDK, but NO by default. The application can configure consent data to be sent from users' device to OneTrust. This consent data can also be linked to an application-provided identifier for that particular user. If an identifier is not provided by the application, the OneTrust SDK will randomly generate an anonymous identifier for the consent data sent to OneTrust. |