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Written Summary of Policies and Procedures

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By Ginny Kozemczak

The International Digital Accountability Council (IDAC) aims to mitigate privacy risks and restore consumer trust in the mobile app ecosystem by investigating and working with developers and online platforms. We conduct investigations based on a broad array of sources, including reports by journalists and advocacy groups, referrals from privacy scholars and partners, or public tips. In determining whether to pursue an investigation, we consider the following factors: 

(1) the severity of the misconduct; 

(2) how many users are likely to be affected;  

(3) the sensitivity of the data implicated; 

(4) the vulnerability of the populations affected; and 

(5) whether others such as law enforcement, advocacy groups, academics have already raised similar concerns. 

Next, our Policy counsel and partner technologists work together to evaluate developer conduct, considering the technical features of the app and the developer’s public representations in light of relevant laws and regulations, platform terms, and industry-wide best practices.

If we suspect that a developer is violating a law, regulation, or platform term, we intervene along a sliding scale of engagement based on the severity of the violation and the potential harm to the public. 

Here’s how we work with key players in this space:

Developers: In most situations, we initially seek to engage the developer to gather more information and, if possible, resolve the issue directly without contacting other parties. 

Platforms: If we have a reasonable suspicion that misconduct is occurring and we are unable to gather information from a developer, then we engage platforms by either requesting information from them or by requesting their assistance in obtaining certain information to determine whether misconduct is occurring. 

Law Enforcement: In more serious and rare cases, we submit referrals to relevant law enforcement authorities and/or notify the public depending on the degree to which evidence of illegality or harm to the public exists. 

For more details on how we operate and investigate, you can read our Policies and Procedures here.