Availability, readability, and content of privacy policies and terms of agreements of mental health apps

Julie M Robillard; Tanya L Feng; Arlo B Sporn; Jen-Ai Lai; Cody Lo; Monica Ta; Roland Nadler

doi:10.1016/j.invent.2019.100243

Availability, readability, and content of privacy policies and terms of agreements of mental health apps

Internet Interv. 2019 Mar 6:17:100243. doi: 10.1016/j.invent.2019.100243. eCollection 2019 Sep.

Authors

Julie M Robillard¹, Tanya L Feng¹, Arlo B Sporn¹, Jen-Ai Lai¹, Cody Lo¹, Monica Ta¹, Roland Nadler²

Affiliations

¹ Division of Neurology, Department of Medicine, The University of British Columbia, B404 - 4480 Oak Street, Vancouver, BC V6H 3N1, Canada.
² University of Ottawa Centre for Health Law, Policy and Ethics, Common Law Section, Faculty of Law, University of Ottawa, 57 Louis Pasteur (Fauteux Hall), Ottawa, ON K1N 6N5, Canada.

Abstract

Objective: To assess the availability, readability, and privacy-related content of the privacy policies and terms of agreement of mental health apps available through popular digital stores.

Materials and methods: Popular smartphone app stores were searched using combinations of keywords "track" and "mood" and their synonyms. The first 100 apps from each search were evaluated for inclusion and exclusion criteria. Apps were assessed for availability of a privacy policy (PP) and terms of agreement (ToA) and if available, these documents were evaluated for both content and readability.

Results: Most of the apps collected in the sample did not include a PP or ToA. PPs could be accessed for 18% of iOS apps and 4% of Android apps; whereas ToAs were available for 15% of iOS and 3% of Android apps. Many PPs stated that users' information may be shared with third parties (71% iOS, 46% Android).

Discussion: Results demonstrate that information collection is occurring with the majority of apps that allow users to track the status of their mental health. Most of the apps collected in the initial sample did not include a PP or ToA despite this being a requirement by the store. The majority of PPs and ToAs that were evaluated are written at a post-secondary reading level and disclose that extensive data collection is occurring.

Conclusion: Our findings raise concerns about consent, transparency, and data sharing associated with mental health apps and highlight the importance of improved regulation in the mobile app environment.

Keywords: Apps; Mental health; Mobile health; Privacy; Smartphone.