NPC DSTSD Guidelines On Instant Messaging Apps
NPC DSTSD Guidelines On Instant Messaging Apps
2021
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
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
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.
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
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
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
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.
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
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.
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
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
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]