Care should be taken that the person completing the questionnaire has accurate information about the company’s practices. Apple stresses that companies are responsible for the accuracy of the information provided to it. We will be watching the launch of this program to see what perspective regulators take about these labels, and potential unfair and deceptive trade practice exposure if they are inaccurate. Responses can be updated at any time.
Putting it Into Practice: Companies that operate mobile apps will need to address these App Store requirements. Care should be taken that the answers submitted into the questionnaire are accurate. To address potential UDAAP exposure, companies will want to track and update their “label” for accuracy just as companies do for their privacy policies.