CNIL's New Recommendations Aim to Protect Your Privacy in Mobile Apps

Key Takeaways

• Who’s Responsible? The CNIL's guidelines clarify the roles and responsibilities of everyone in the mobile app ecosystem, from developers to operating system providers.
• Transparency Is Key Apps must be clear about how they use your data and ensure that permission requests are easy to understand.
• Consent That Works Users must be able to give and withdraw consent easily — no more forced agreements for non-essential data.
• From Guidelines to Action The CNIL will begin enforcing these rules in 2025, with a focus on making mobile apps safer for users.

Deep Dive

Our smartphones are more than just devices, they’re an extension of ourselves. We rely on them to navigate daily life, from communication and entertainment to shopping and tracking our health. In 2023, the average French citizen downloaded 30 mobile apps and spent over 3 hours a day using their phones. But while we’re all living more digitally connected lives, there’s a downside i.e., privacy risks. With apps constantly collecting our data, how can we make sure our personal information stays safe?

The French National Commission on Informatics and Liberty (CNIL) is stepping up with some much-needed guidelines for mobile apps. After consulting with stakeholders, the CNIL has rolled out new recommendations designed to help mobile app developers and publishers navigate the tricky waters of data protection. And starting in 2025, they’ll make sure these guidelines are enforced, ensuring that privacy doesn’t take a backseat in our increasingly digital world.

Mobile apps can access a wealth of sensitive data, from your real-time location to your contacts, photos, and health information. And let’s face it: the permissions apps request to access these data points are often extensive. The more stakeholders involved in an app’s operation, the more complicated the privacy picture becomes.

What makes the CNIL’s new recommendations so important is that they address these issues head-on. They aim to make the mobile app ecosystem safer by ensuring that privacy protection is built in from the very start, from development to launch. Here's what the new recommendations are all about:

1. Everyone Has a Role to Play: The CNIL isn’t just talking to app developers; it’s reaching out to everyone involved in the mobile app ecosystem. From the app publishers who distribute them to SDK providers (those behind the building blocks that developers use), all the way to operating system providers like iOS and Android, the recommendations set out clear roles and responsibilities for each player. That means everyone involved knows exactly where they stand when it comes to privacy obligations.
2. Clear and Simple User Communication: The CNIL emphasizes the importance of clear communication with users. Users deserve to know what their data is being used for, and it should be easy for them to understand. When apps ask for access to sensitive information like your location or contacts, they need to explain why. Is it really necessary for the app’s core functionality, or is it just for advertising purposes? Transparency is key, and users should be able to make informed choices.
3. Consent That’s Easy to Give and Take Back: One of the biggest changes in CNIL’s recommendations is how consent is managed. Apps must make sure they aren’t forcing users to accept data collection that isn’t essential. Consent for things like personalized ads must be given freely and can be withdrawn just as easily as it was given. No more hiding behind complicated opt-outs, users should always have control.

The CNIL didn’t just make these recommendations in a vacuum. They consulted with a wide range of stakeholders in the mobile app world (developers, publishers, privacy experts, and more) to gather insights and ensure the guidelines were practical and effective. Plus, they collaborated with the French Competition Authority (ADLC) to address the overlap between privacy and competition law. It’s all part of a broader effort to make the digital ecosystem work better for everyone.

In the coming months, the CNIL will be ramping up efforts to help the industry comply with these recommendations. Expect webinars and other resources to help stakeholders implement the necessary changes. And come 2025, the CNIL will begin investigating mobile apps for compliance, ensuring that users’ privacy is protected.

These guidelines may be new, but they represent a much-needed shift in how we approach privacy in the digital world. It’s time for developers, publishers, and all stakeholders to take action and ensure that privacy is not just a checkbox, but a core part of how mobile apps are built and used.

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