Apple Nutrition Labels: Just The Facts

On December 8, the new Apple privacy label policy (AKA “nutrition labels”), initially announced this summer, went into effect. The Apple privacy label policy requires app developers to self-report the categories of data and information their apps collect. According to Apple, app developers “need to provide information about your [the developer’s] app’s privacy practices, including the practices of third-party partners whose code you [the developer] integrate into your app, in App Store Connect. This information will be required [for developers] to submit new apps and app updates to the App Store.”

Why Is Apple Requiring Nutrition Labels?

Apple has been very clear about their intentions to move toward more privacy for users across the Apple universe. Despite the tech giant delaying the controversial identification for advertisers (IDFA) update that will essentially require permission to track users, moving ahead with the nutrition label is a sign that Apple is going to continue to push for increased privacy and transparency for users.

This expansion of privacy features by Apple can be chalked up to a number of reasons, including the desire to mitigate privacy breaches, give users more opt-in control when sharing their personal information and avoiding the attention of the FTC, which has been concerned about tech privacy in recent years. Third-party cookies, due to overall concerns about privacy and tech, will be sunsetted in the coming years. In response, tech companies like Apple are creating transparency for users, giving them control over when and to whom they provide data that could make it easier for brands to get the data they need, transparently, without infringing on users’ personal information. 

After some side-eye from WhatsApp about whether Apple will also require its own apps to have nutrition labels, Apple reiterated that the labels would be required on all apps, whether developed by Apple or third-party developers, noting “The new [privacy label] rules apply equally to all iOS apps, including all Apple‘s built-in apps like Messages. For iOS apps that don’t have dedicated product pages on the App Store, like Messages, they will still have the same privacy information be made available to users on Apple’s website.” 

What Information Will App Developers Be Required To Disclose On Apple’s Nutrition Labels?

App developers will be required to disclose a lot of details on the new Apple nutrition labels. And, according to Greg Sterling for Martech Today, in addition to data-collection disclosures relevant to the app’s intent, “publishers will also need to report the data captured and transmitted to third-party partners, which include ‘analytics tools, advertising networks, third-party SDKs [software development kits], or other external vendors whose code you’ve [the developer has] added to your app.’”

The data categories that Apple requires be disclosed are quite comprehensive, including:

• Contact/identity information
• Health and fitness information
• Location data
• Financial information (e.g., payments, credit score, etc.)
• Any “sensitive info” (demographic data, opinions, sexual orientation, biometric data, etc.)
• Data tied to collection of information on a user’s contacts
• User-generated content (email, texts, photos, videos, etc.)
• Search or browsing history
• User or device IDs
• Purchase history data (e.g., e-commerce/retail apps)
• Usage/analytics data (e.g., launches, clicks, views, etc.)
• Diagnostic data (e.g., crash information)

There are some cases in which “optional disclosure” is possible, which means some publishers may not need to tack a nutrition label onto their app. These rare exceptions are mostly related to data that isn’t used for tracking or that is expressly shared by the users. However, as Apple notes, “If a data type collected by your app meets some, but not all, of the [optional disclosure criteria], it must be disclosed.”

Why Are The Apple Nutrition Labels Important To Digital Advertisers?

Although it’s likely that most app users will scroll on by disclosures, the move toward more stringent data collection and tracking has an impact on all digital advertisers. Right now, advertisers rely on third-party data when advertising with apps. As that gets increasingly difficult, advertisers are going to have to adapt campaigns to yield and leverage first-party data that can be used for audience targeting and personalized outreach. Advertising strategies that incorporate propensity marketing, machine learning and smart tech that builds audiences and engages without relying on cookies and other third-party trackers, are where advertising is headed. Advertisers need to be ready. 

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