Adopted in May 2018, the European Union's General Data Protection Regulation (GDPR) requires the consent for processing users' personal data to be freely given, specific, informed, and unambiguous. While prior work has shown that this often is not given through automated network traffic analysis, no research has systematically studied how consent notices are currently implemented and whether they conform to GDPR in mobile apps. To close this research gap, we perform the first large-scale study into consent notices for third-party tracking in Android apps to understand the current practices and the current state of GDPR's consent violations. Specifically, we propose a mostly automated and scalable approach to identify the currently implemented consent notices and apply it to a set of 239,381 Android apps. As a result, we recognize four widely implemented mechanisms to interact with the consent user interfaces from 13,082 apps. We then develop a tool that automatically detects users' personal data sent out to the Internet with different consent conditions based on the identified mechanisms. Doing so, we find 30,160 apps do not even attempt to implement consent notices for sharing users' personal data with third-party data controllers, which mandate explicit consent under GDPR. In contrast, out of 13,082 apps implemented consent notices, we identify 2,688 (20.54%) apps violate at least one of the GDPR consent requirements, such as trying to deceive users into accepting all data sharing or even continuously transmitting data when users have explicitly opted out. To allow developers to address the problems, we send emails to notify affected developers and gather insights from their responses. Our study shows the urgent need for more transparent processing of personal data and supporting developers in this endeavor to comply with legislation, ensuring users can make free and informed choices regarding their data.
The 29th ACM Conference on Computer and Communications Security (CCS)