Understand the GDPR Warnings

Assessor View's DPV View classifies every program slice into the following five GDPR warnings:

1. Data collection GDPR Article 13 Severity: Medium

⚠️ This part of the app code is collecting data.

Legal recommendation for developers: Ensure transparency by reporting this data collection through the privacy policy and Google Play Store's data safety section.

Legal recommendation for DPOs: Check reporting documents to decide adherence to GDPR Article 13.

2. Data collection but no processing GDPR Article 5 Severity: Low

⚠️ This part of the app code is collecting data but may not be processing it.

Legal recommendation for developers: Explain why data collection is necessary.

Legal recommendation for DPOs: Developers should be asked if data minimization is possible. Check for violation of GDPR Article 5.

3. Processing of data in the absence of technical measures GDPR Article 25 GDPR Article 32 Severity: High

⚠️ This part of the app code is collecting and processing data, in the absence of technical measures (pseudonymization).

Legal recommendation for developers: Explain why data has not been pseudonymized.

Legal recommendation for DPOs: Developers should be asked to clarify the legal basis and purpose for not applying pseudonymization. The absence of a valid legal justification for not implementing technical measures could constitute a violation of GDPR Articles 25 and 32.

4. Processing of data after implementing technical measures GDPR Article 25 GDPR Article 32 Severity: Low

⚠️ This part of the app code appropriately implements technical measures (pseudonymization) before processing data.

Legal recommendation for developers: Document technical measures.

Legal recommendation for DPOs: Compliant with GDPR Articles 25 and 32.

5. Processing of data before implementing technical measures GDPR Article 25 GDPR Article 32 Severity: High

⚠️ This part of the app code is collecting and processing data before the implementation of technical measures (pseudonymization).

Legal recommendation for developers: Explain why data has been pseudonymized after processing.

Legal recommendation for DPOs: Developers should be asked to clarify the legal basis and purpose for not applying pseudonymization before processing data. The absence of a valid legal justification for not implementing technical measures could constitute a violation of GDPR Articles 25 and 32.

Best Practices for Developers

The General Data Protection Regulation requires app vendors to protect the personal data (risk 1 and risk 2 data) they collect from the users. As an app developer, you must:

Report data collection

Article 13 of the GDPR mandates apps to report the collected personal data to users via documents such as privacy policies and Google's data safety section.

Minimize data collection

Articles 5 and 25 of the GDPR mandate apps to only collect the personal data that is required for the functionality of the app.

Pseudonymize the collected data

Articles 24 and 32 of the GDPR mandates apps to protect the collected data by pseudonymizing it.

Learn More About GDPR