Commissioner’s Findings - PIPEDA Case Summary #2014-007 : Apple called upon to be more open about its collection and use of information for downloads
An individual complained that Apple unnecessarily required payment information and date of birth to download free applications. The OPC found that Apple's privacy policy did not fully identify the purposes for collecting date of birth for authentication, leading to a well-founded and conditionally resolved finding after Apple agreed to revise its policy. Regarding payment information, the OPC determined that Apple did not make instructions for downloading free apps without providing payment details clearly accessible. This aspect was also found to be well-founded, and Apple agreed to implement a clear option for users to proceed without supplying payment information at registration. The OPC was pleased with Apple's commitment to address the issues.
- 1Whether Apple's privacy policy adequately identified the purposes for collecting date of birth information for authentication (Principle 4.2 PIPEDA)
- 2Whether Apple's collection of date of birth was limited to what was necessary for identified purposes (Principle 4.4 PIPEDA)
- 3Whether Apple made information about its policies and practices concerning the collection of credit card information readily available to individuals (Principle 4.8 PIPEDA)
- 4Whether Apple's practices resulted in the over-collection of sensitive payment information (Principle 4.4 PIPEDA)
- Collection of DOB: Policy on DOB collection found inadequate
- Collection of payment info: Policy on payment info collection found inadequate
- Resolution of DOB issue: Apple agreed to revise policy
- Resolution of payment info issue: Apple agreed to implement clear option
Complaint well-founded and conditionally resolved regarding date of birth collection; well-founded and resolved regarding payment information collection.
Apple's privacy policy was found to be deficient in identifying the purpose for collecting date of birth, and its method for informing users about avoiding payment information for free downloads was not sufficiently clear or accessible, leading to potential over-collection.
Apple agreed to revise its privacy policy to clearly identify the purpose for collecting date of birth and to implement a clear option for users to register for an Apple ID to download free applications without providing payment information at every point of registration.
- Principle 4.2 PIPEDA
- Principle 4.4 PIPEDA
- Principle 4.8 PIPEDA
This summary is informational only and not legal advice.
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