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NPC DSTSD Guidelines On Instant Messaging Apps

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110 views15 pages

NPC DSTSD Guidelines On Instant Messaging Apps

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You are on page 1/ 15

ISSUE NO: DSTSD-DPSA– 001s.

2021

GUIDELINES ON MESSAGING APPS


Version 1.0

REVISION HISTORY LOG

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

LOG NO. DATE SECTION DETAILS AUTHOR


1 15 February 2021 I-II and VII a. Overview, Issue, Kelvin Magtalas
Google Android
Permissions
2 14 March 2021 III-X Definition of Terms, Janssen Esguerra
Scope, Objectives,
Method, Added
Apple iOS,
Information
Contained in App
Stores, Analysis and
Key Findings, Good
Practice Guide for
Developers and
Users
3 06 April 2021 All Revisions Jonathan Ragsag

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

TABLE OF CONTENTS

GUIDELINES ON MESSAGING APPS..........................................................................................................1


REVISION HISTORY LOG.......................................................................................................................2
I. OVERVIEW......................................................................................................................................4
II. ISSUE...............................................................................................................................................4
III. DEFINITION OF TERMS.............................................................................................................5
IV. SCOPE..........................................................................................................................................5
V. OBJECTIVES....................................................................................................................................5
VI. METHOD.....................................................................................................................................5
VII. INFORMATION CONTAINED IN APP STORES..........................................................................6
a. GOOGLE PLAY STORE (ANDROID OS) .....................................................................................6
b. APPLE APP STORE (iOS OS) .....................................................................................................7
c. KEY FINDINGS............................................................................................................................8
VIII. PERMISSIONS SOUGHT BY MESSAGING APPS.........................................................................8
a. GOOGLE PLAY STORE................................................................................................................9
b. APPLE APP STORE.....................................................................................................................9
c. KEY FINDINGS..........................................................................................................................10
IX. Good Practice Guides (GPG)....................................................................................................12
a. For Messaging App Developers...............................................................................................12
b. For Messaging App Users.........................................................................................................13
X. CONCLUSION................................................................................................................................15

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

I. OVERVIEW
Messaging Apps In the first week of January 2021, WhatsApp briefly became
a trending app among its users because of its new privacy
Social messaging or chat policy.
applications, more commonly
known as “messaging apps”, are WhatsApp Inc. gave the users at least three months to
software applications that properly review and accept the policy following user
provide instant messaging (IM) / backlash and confusion. WhatsApp was forced to explain
real-time text transmission over what data it collects and how it shares that information with
the Internet. its parent company, Facebook Inc.

The term instant messaging


originated from the 1990s and
predates the Internet. Early II. ISSUE
programs were primarily real- WhatsApp announced that its privacy policy update will
time, as characters appeared as take effect on 15 May 2021 instead of 08 February 2021
they were typed. which was the previously set date.
The updated policy terms informed users that WhatsApp
In the emergence of smart
phones in the late 2000s and receives information from, and shares information with, the
early 2010s, numerous startups Facebook family of companies. These changes were focused
developed online mobile on introducing new options for businesses using WhatsApp
messaging apps that replaced Business.
instant messaging and SMS.
WhatsApp claims that its messaging platform is end-to-end
encrypted, meaning only the sender and recipient can read
the message and it is not stored on Facebook servers. But
WhatsApp is also pushing messaging for businesses
aggressively. The updated privacy policy was intended to
alert users that some businesses would soon be using
Facebook-owned servers to store messages with customers.
Facebook has already said that it will not access those
messages for any type of ad targeting or profiling, but the
language in the updated terms of service concerned many
users who worry that Facebook would suddenly view or
access their private messages.

Emergence of online messaging apps in


early 2010s

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

III. DEFINITION OF TERMS


1. App store (or app marketplace) is a general term for a type of digital distribution platform
or a digital shop where users can buy & download digital software and applications.
2. App (abbreviation for application) refers to a software that provides additional
functionality to an operating system. The term app originally referred to any mobile or
desktop application. But as more app stores have emerged to sell mobile apps to
smartphone and tablet users, the term has evolved to refer to a small program that can be
downloaded and installed all at once.
3. OS (abbreviation for Operating System) refers to the software that allows a user to run
other apps on a computing device such as a smartphone.
4. Smartphone is a mobile phone with highly advanced features. A typical smartphone has a
high-resolution touch screen display, Wi-Fi connectivity, web browsing capability, and the
ability to accept sophisticated apps. The majority of these devices run on any of these
popular mobile OS: Android, Symbian, iOS, BlackBerry OS and Windows Mobile.

IV. SCOPE
These guidelines apply only to the mobile versions of the messaging applications.
Desktop versions of the messaging applications are excluded from these guidelines.

V. OBJECTIVES
In view of the foregoing, these guidelines aim to provide readers with information and
awareness on the following:
1) general information given by app stores;
2) permissions sought by each messaging app;
3) categories of personal information of data subjects that the messaging apps process;
and
4) good privacy practices in the use of messaging apps.

VI. METHOD
To be able to provide key findings and recommendations, six (6) messaging apps on
Google’s Android OS and Apple’s iOS OS were sampled. The rationale for their sampling
or selection is due to their popularity and use in the Philippines. The following
messaging apps on Google Play Store (for the Android OS) and Apple App Store (for the
iOS OS) were assessed:
1.) Messenger; 4.) WhatsApp;
2.) Telegram; 5.) WeChat; and
3.) Viber; 6.) Signal

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

VII. INFORMATION AVAILABLE ON THE APP STORES


Each app store uniquely presents the mobile apps that are available. Tables 1 and 2 below
enumerate and describe the information available on Google Play Store and Apple App Store,
respectively:

a. GOOGLE PLAY STORE (ANDROID OS)


Top Information Brief Description
Icon Icon image of the app
Name Name of the app
Offered by Entity name of the app developer/provider
Category Category of the app where it is classified or tagged under
Age Rating Provides age-based rating
Average Users’ Average score given by the users who chose to rate the app in 1-5 stars,
Rating where 5 is the highest rating
Screenshots Screen captures of the app with featured introductory functions
Introduction Provides an overview of the app
Reviews Provides user ratings and reviews on the app
Additional Information
Updated Date when the app is updated to its latest version
Current Version Refers to the latest build or version number of the app
Interactive Elements Include things like whether an app shares a user's location, or if it allows
users to interact with each other, i.e.: users interact, shares location, in-
app purchases, etc.
Report Provides avenues for reporting content issues or violations
Size Approximate size of the applications in megabytes (M) or gigabytes (G)
Requires Android Minimum build or version number of the Android OS to run this app
In-app Products Approximate cost range of in-app purchases available on the app
Offered By Name of the application developer
Installs Approximate number of user installs
Content Rating Provides content rating of the app, which varies by age of users, its
interactive features, and rating regulations by country or region
Permissions Lists all of the permissions required in using the app
Developer/s Provides links to the providers’/developers’ website, email address,
privacy policy and location
Table 1. Google Play Store information on an app

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

b. APPLE APP STORE (iOS OS)


Top Information Brief Description
Icon Icon image of the app
Name Name of the app
Offered by Entity name of the app developer
Category Category of the app where it is classified or tagged under
Age Rating Provides age-based rating
Average Users’ Average score given by the users who chose to rate the app, in 1-5 stars,
Rating where 5 is the highest rating
Screenshots Screen captures of the app with featured introductory functions which
vary among Apple devices: iPhone, iPad and Apple Watch
Introduction Provides an overview of the app
What’s New Provides description and extent of the changes that the developer made
on the current version of the app
Version Refers to the latest build or version number of the app
Version History Provides a list of all the app versions that were released
Ratings and Reviews Provides user ratings and reviews on the app
App Privacy Provides a link to the developer’s privacy policy, Privacy Definitions and
Examples, Learn More About App Privacy : App Store Story (apple.com),
Data Used to Track You, Data Linked to You, and Data Not Linked to You
Additional Information
Provider Entity name of the app developer/provider
Compatibility Minimum build or version number of the iOS OS to run this app
Location Provides notice on how the app uses the device’s location
Size Approximate size of the applications in megabytes (MB) or gigabytes
(GB)
Languages Available languages that the app can be used to display
Copyright Provides copyright information
Category Category of the app where it is classified or tagged under
Age Rating Provides age-based rating and description
Price Specifies whether the app is free to use and install or requires payment
before use and install
Table 2. App Store information of an app

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

c. KEY FINDINGS
i. One of the general data privacy principles of the Philippines’ Data Privacy Act of
2012 (DPA) and most data protection regimes around the world is transparency.
Therefore, the messaging apps provide a common and standard set of information
that data subjects or users ought to know before deciding to give their consent: to
install the app, allow permissions sought by the app, provide personal information
and use the app occasionally or regularly.
“Top Information” refers to the most important information at the top portion of the
landing page of the app while “Additional Information” refers to other useful
information regarding the app.
For users, the most important details available on the app stores are as follows:
1) permissions sought (whether these are excessive based on the app’s
purpose/s or functionalities);
2) other user ratings and reviews (for user experience red flags);
3) content/age rating (whether the app is suitable for minors or children); and
4) the privacy policy (which contains the overall information on privacy and
data protection).
ii. Some details under top information are also posted under additional information,
showing the importance of these to app users. They are as follows:
1) Developer (Google Play Store) and Provider (Apple App Store) – usually
denotes the Personal Information Controller;
2) App Category – reveals the purpose of the app;
3) Content/Age Rating – minimum maturity level of content provided by the
apps; and
4) Whether the app is free or offers in-app purchases.

VIII. PERMISSIONS SOUGHT BY MESSAGING APPS


Each app store uniquely discloses the permissions requested by messaging apps or apps
in general. Tables 3 and 4 show the permissions sought by the Android OS version of the
app and the iOS version of the app, respectively.

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

a. GOOGLE PLAY STORE


Facebook
Messaging Apps Telegram Viber WhatsApp WeChat Signal
Messenger
Permissions
WiFi      
Contacts      
SMS      
Phone      
Microphone      
Device ID & call
information
     
Location      
Calendar      
Camera      
Device & app history      
Photos/Media/Files      
Identity      
Wearable
sensors/Activity data
     
Other      
Table 3. Permissions sought by messaging apps on Google Play Store

b. APPLE APP STORE


Faceb
ook Signal
Messaging Apps Telegram Viber WhatsApp WeChat
Messe
nger
Data Used to Track You      
Data Linked to You      
Data Not Linked to You      
Permissions
Browsing History         
Contact Info         
Contacts         
Diagnostics         
Financial Info         
Health & Fitness         
Identifiers         
Location         
Other Data       
Purchases         
Search History         
Sensitive Info         
Usage Data         
User Content         
Table 4. Permissions sought by messaging apps on Apple App Store

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

c. KEY FINDINGS
i. The Apple App Store app permissions can be found on App Privacy>See Details.
The App Privacy of the Apple App Store has three (3) categories of permissions
sought, branded as “Privacy Nutrition Labels1”:
1) Data Used to Track You – data may be used to track you
across apps and websites owned by other companies;
2) Data Linked to You – data may be collected and linked to
your identity; and
3) Data Not Linked to You – data may be collected but not
linked to your identity.
The Google Play Store app permissions can be found on ADDITIONAL
INFORMATION > View details.
Both app stores have indicated specific permissions sought by messaging apps
and their descriptions. However, in terms of demonstrating transparency and
adequately informing the data subjects, Apple/App Store/iOS has the edge. By
being granular while maintaining a clear and plain language, it is a trailblazer in
this aspect. While Google/Play Store/Android OS lags currently, it is now
working on its own “privacy nutrition labels2”.

ii. The Google App Store and the Apple App Store both provide a breakdown of
permissions sought by each messaging app. While both have a common and
standard set of terminologies used, they differ in nomenclature. Some names of
permissions may be synonymous with each other in both app stores, i.e.: the
permission “Photos/Media/Files” on the Google Play Store is equivalent to “User
Content” on the Apple App Store and “Device ID & call information” on the
Google Play Store is equivalent to “Identifiers” on the Apple App Store.

iii. Common Permissions sought by messaging apps (6/6): WiFi, Contacts/Contact


Information, Phone, Microphone, Device Identifiers & Call Information, Camera,
Photos/Media/Files, Identity and Other are expected permissions due to the
minimum functionality or actions users perform when interacting or using a
messaging app, i.e.: WiFi is needed to establish connection to the internet,
Phone/Microphone are needed to transmit and receive voice or audio data,
Camera/Files are needed to transmit or receive photo or video data, etc.

iv. Identity (6/6): All messaging applications use this permission. It provides phone
status and identity. This works by processing the unique identifier associated to
a user’s mobile device, the International Mobile Equipment Identifier (IMEI).

v. Location Permission (5/6): Signal is the only messaging app that does not
collect location information. Most of the apps listed here collect location
information primarily because of the application function that sends the exact
location, for example in meetups.

1
Apple's Privacy Nutrition Labels, available now and good for business | Computerworld
2
Google is working on its own privacy 'nutrition' labels for the Play Store | Android Central
5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

vi. Device & App History Permission (4/6): Allows the app to retrieve information
about currently and recently running tasks. This may allow the app to discover
which applications are used on the device. This is a spyware-like permission
that has been deprecated by Android 3. Possible reasons why developers have
not totally removed this permission are debugging, testing, or backward
compatibility on legacy Android OS versions.

vii. SMS Permission (3/6): Granting SMS permission will enable the applications to
read the inbox and send & receive SMS messages. Messenger, WhatsApp, and
Signal may require access to the device’s SMS inbox if a user chooses to use
either one of them as the default SMS client/app.

viii. Wearable Sensors / Activity Data (1/6): Among the messaging apps, only
WeChat has access to this permission. This may be attributed to the “WeRun”
fitness module or plugin integrated in WeChat. It is mainly touted for fitness
tracking and health.

ix. Other: Both iOS OS and Android OS messaging apps have permission for “Other”.
All uncategorized permissions are lumped and itemized under this permission.

3
https://developer.android.com/reference/android/app/ActivityManager.html#getRunningTasks(int)
5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

IX. Good Practice Guides (GPG)


a. For Messaging App Developers
Build privacy in the core of app development (privacy by design). Privacy
should not just be an afterthought.
i. Request minimum permissions. Every time you’re asking for a permission,
you are forcing users to decide. Reduce the user’s burden. If your app really
needs to access a specific permission, ask it in increments. Look for
alternatives in use cases that will help limit the number of permissions you
ask. Use statistics to derive the rate of denial of a specific permission and
influence subsequent updates & approach to that permission.
ii. Ask for access only in context. Ask for a specific permission, when the in-app
features demand for it, only due to a user action (i.e., in meetups, users press
location sharing in their messaging apps to know their proximity or location
relative to each other). Tweak the user interface in such a way that it
provides appropriate explanation to the user and is designed to never be
forced or accidentally permitted.
iii. Plan for users to select deny. Whenever possible, minimize the time or
access window of application permissions. Let the user choose to allow a
permission through any of the following options:
 While using the app. Once the user selects this option, the messaging app
will have access to the specific permission only if the app is in the
foreground or active window or in use.
 Only this time. The messaging app will have access only for a short
period and access will automatically be revoked.
 Deny. Access of the messaging app to the requested permission is
denied.
 Handling “deny”
o Do not block users from using your app. There are
instances when the app forces users to allow the
requested permission or else the users won’t be able to
use the app at all. Users must still be able to use the app
(ex. denying microphone or storage permission will still
let users browse their messages and chat through the
messaging app).
o Expect permanent deny, don’t push users to settings. Ask
for permission in context and allow the permission to be
declined within the app interface.
iv. Access sensitive permissions only when the user expects it. The messaging app
must be able to provide instantaneous apermissccess to sensitive permissions
such as camera and microphones. It must provide continuous visual indicators
that applications are actively accessing these permissions.

v. Pay attention to libraries. Audit current data especially sensitive data accessed
by third-party API and libraries.

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

b. For Messaging App Users


Take note that these are guidelines and your specific needs may vary depending
on your risk appetite.
i. Messenger (Facebook)
 Preferably, access your Facebook messages using a browser or the “lite” version
of Facebook Messenger.
 Preferably, use “Messenger Kids” for children.
 Profile: Set Active Status: Off
 Privacy:
o Message Delivery
 Friends of Friends on Facebook: Don’t Receive Requests
 Your followers on Instagram: Don’t Receive Requests
 Others on Facebook and Instagram: Don’t Receive Requests
o Story Audience: Friends Only
o SMS: Off
 Contacts: Set Sync Contacts to off
 Photos and Media: Open Links in Default Browser: On
ii. Telegram
 Privacy
i. Phone Number: Nobody
ii. Last Seen & Online: Nobody
iii. Profile Photos: My Contacts
iv. Forwarded Messages: Nobody
v. Calls: Nobody
vi. Groups
1. Who can add me to group chats: My Contacts
 Security
i. Passcode Lock: On
1. Unlock with fingerprint: Off
2. Show app content in Task Switcher: Off
ii. Two-Step Verification: On
iii. Review all active sessions and terminate those that are unknown or inactive
to you
iv. Set a preferred period for Account Self-Destruct
v. Contacts
1. Sync Contacts: Off
2. Suggest Frequent Contacts: Off
iii. Viber
 Viber backup: Chat back up is discouraged since it will link to your Google Drive.
 Desktop and tablets: Review active logins and deactivate sessions that are unknown
or inactive to you.
 Privacy
i. Share online status: Off
ii. Send “seen” status: Off
5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

iii. Show your photo: Off


iv. Share your birth date: Off
v. Auto spam check: On
vi. Use peer-to-peer: Off
vii. Allow friend suggestions: Off
viii. Trusted Contacts: Off
ix. Control who can add you to groups: My contacts
x. Personal data
1. Collect analytics: Off
2. Allow content personalization: Off
3. Allow accurate location-based services: Off
iv. WhatsApp
 Privacy
i. Last seen: Nobody
ii. Profile photo: Nobody
iii. About: Nobody
iv. Read receipts: Off
v. Groups: My contacts
vi. Live location: None
vii. Fingerprint lock: Disable
 Security
i. Show security notifications: On
ii. Two-step verification: On
 Request account info: Request report to see what data WhatsApp holds about you.
 Chat back up is discouraged since it will link to your Google Drive.

v. WeChat
 Privacy
i. Friend Confirmation: On
ii. Methods for friending me
1. WeChat ID: Off
2. Mobile: Off
3. Group Chat: Off
4. QR Code: Off
5. Contact Card: Off
iii. Moments and Time Capsule
1. Hide My Posts: Choose contacts who could not watch your Moments
posts.
2. Hide Their Moment: Choose contacts whose Moments you do not
want to see.
3. Viewable by Others: Limit the period of Moments that are viewable
to others.
vi. Signal
 Privacy
i. App access

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]
ISSUE NO: DSTSD-DPSA– 001s.2021

1. Screen lock: On
2. Screen lock inactivity timeout: Put a screen lock period
3. Screen security: On
4. Incognito keyboard: On
ii. Communication
1. Always relay calls: On
2. Read receipts: Off
3. Typing Indicators: Off
4. Generate link previews: Off
iii. Signal PIN
1. PIN reminders: On
2. Registration Lock: On

X. CONCLUSION
 Less is more when it comes to privacy of messaging apps. Parents should review the
settings of their children’s’ messaging apps and tweak them according to this guide.
 Review the permissions of messaging apps. Grant the minimum permissions needed to be
able to use the append and revoke permissions that are not in use. Allow them only in the
instance that you are going to use them although this may be a tedious task and places a
burden on the user. Developers of operating systems of smart phones are enjoined to
provide options to users in granting instantaneous access to the permissions and
automatically revoking them after use.
 Be vigilant when conversing with strangers. Verify their identities first before providing any
information about yourself.
 Do not tap links & files in messaging apps if you are not expecting them and especially if
they came from a stranger. You can be phished, or a malware can infect your device.
 Be careful in joining a group as all group members will gain access to your phone number.

5th Floor, Philippine International Convention Center, Vicente Sotto Avenue Pasay City, Metro Manila 1308
URL: https://privacy.gov.ph Email Add: [email protected]

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