Understanding Challenges for Developers to Create Accurate Privacy Nutrition Labels

Apple announced the introduction of app privacy details to their App Store in December 2020, marking the first ever real-world, large-scale deployment of the privacy nutrition label concept, which had been introduced by researchers over a decade earlier. The Apple labels are created by app developers, who self-report their app's data practices. In this paper, we present the first study examining the usability and understandability of Apple's privacy nutrition label creation process from the developer's perspective. By observing and interviewing 12 iOS app developers about how they created the privacy label for a real-world app that they developed, we identified common challenges for correctly and efficiently creating privacy labels. We discuss design implications both for improving Apple's privacy label design and for future deployment of other standardized privacy notices.