Explained: What are iOS 17 Privacy Manifests, and how do they impact app developers?
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Explained: What are iOS 17 Privacy Manifests, and how do they impact app developers?

CIO Review

Verve Apple is taking steps to enhance transparency and user control over data sharing in its app store. The ultimate goal is to ensure that app users have a complete understanding of and control over the data they share, preventing them from unwittingly exchanging their data for access to app content. In this context, we will explain how this objective is achieved through the use of Privacy Manifests, the required reasons API process, and other privacy tools integrated into iOS 17. Additionally, we will explore the implications for third-party SDKs from both the perspective of app developers and SSPs (Supply-Side Platforms) as Verve Group prepares to support these new privacy measures.

Privacy Manifests and Addressing Probabilistic Attribution

Privacy Manifests aim to offer greater transparency regarding the collection and utilization of user data. In a way, Privacy Manifests are poised to significantly complicate, and possibly eliminate, probabilistic attribution and fingerprinting, which became essential for some advertisers and Mobile Measurement Partners (MMPs) following the release of iOS 14.5 and the introduction of App Tracking Transparency (ATT).

While ATT enables users to decide whether their data is tracked across apps and websites for advertising purposes, Privacy Manifests will assist app developers in creating more informative and standardized Privacy Nutrition Labels. These labels will provide app users with a clearer understanding of the data accessed by the app.

The industry faced a dilemma when it came to user consent for ATT, with reports suggesting that only about 34% of users granted consent. This lack of consent left ad platforms and app marketers uncertain about the performance of their user acquisition campaigns.

To address this issue, some MMPs and ad networks turned to "probabilistic attribution," a practice often associated with fingerprinting. Essentially, this approach involved collecting certain data when a user clicked on an ad and other data when the app launched, then probabilistically matching these two sets of data.

However, probabilistic matching is not compliant with Apple's regulations, and the changes being implemented by Apple are expected to put an end to this workaround. As a result, advertisers may be left with SKAdNetwork as the sole viable option for measuring campaigns on users who opt out of tracking.

For app developers, the new policy is anticipated to be enforced through the App Store review process starting in spring 2024, as outlined in Apple's "Get started with Privacy Manifests" guide. However, some actions have been available since fall 2023 as recommendations.

Understanding Privacy Manifests

The introduction of Privacy Manifests and the required reasons APIs is expected to have an impact similar to that of the introduction of ATT in 2021. Let's first delve into Privacy Manifests.

Privacy Manifests are essentially files created in Xcode that every SDK and app developer will need to complete and include in their apps. These files describe the user data accessed by the app and how the app developer intends to use it. An apt comparison is the Nutrition Label on food products, where consumers check for information like sugar or carbohydrate content while grocery shopping. Similarly, users can easily review the data points they will be sharing when deciding to install an app from the App Store. Apple's move emphasizes transparency and education for consumers, allowing them to make informed decisions regarding privacy.

Privacy Manifests will document the privacy practices of an app's code. When app developers prepare their apps for submission to the App Store, Xcode will consolidate the privacy manifests of all third-party SDKs used in the app into a comprehensive privacy report. Developers will refer to this report when providing privacy details for their apps in App Store Connect.

The Required Reasons API Process

In addition to Privacy Manifests, there is a required reasons API process that further emphasizes "privacy by design" principles. For instance, does a calculator or flashlight app need access to a user's keyboard APIs to check the languages they are typing in? To prevent unnecessary data access by apps, there is now a list of APIs that require declaration and a list of approved reasons for their use.

When apps utilize APIs that could potentially be used for fingerprinting (which is prohibited by Apple), developers must provide a legitimate reason for using the API in question and indicate it in their privacy manifest. Subsequently, the app can only use the API for the purposes declared in its privacy manifest.

Starting in fall 2023, developers will receive notifications when an app uses a required reasons API without sufficient explanation in the privacy manifest. By 2024, the declaration of required reasons in the privacy manifest will become mandatory.

Accountability and Enforcement

Mandating that apps and SDKs specify their data requirements and reasons for access is expected to diminish the practice of probabilistic matching and fingerprinting. Enforcement will occur both at the operating system level (consumer level) and the app store level (publisher level).

Apps will be held accountable for the third-party SDKs they incorporate. Apps lacking or with misleading Privacy Manifests, including reports on their third-party SDKs, will not pass the App Store publishing review.

Apple's review process is renowned for its thoroughness. Developers aiming for a speedy app approval and release will need to avoid the risk of delaying app store publishing due to failed editor reviews or, in the worst-case scenario, having their apps banned from the app store. This is likely to bring about a shift in developer focus towards the privacy practices of each third-party SDK they use. If ATT consent is not granted, iOS will block requests to tracking domains containing additional device or user information that could be used for fingerprinting. In essence, when ATT consent is not granted, the OS will block internet connections to URLs with certain domains specified in the SDK's privacy manifest tracking domains list.

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