Google’s requirement for data safety information has been announced in 2021 and in October the form that publishers need to fill out has been made available. It was said the form should be filled out by February 2022 and any app that doesn’t have its Data safety section filled out properly by April 2022 will be delisted.
Like many small indie developers, we at Gameljne Games use AdMob to serve ads. We assumed that AdMob will provide correct answers to the data safety form since they know this must be done. They are, after all, a part of Google as well. The official Prepare for Google Play’s data disclosure requirements page does not have enough information and many discussion groups asking for more detailed information could be found all over the internet.
But the 1st of February has arrived, and no official answers were given. So, we sat down, read all AdMob policies we could find, searched through forums, groups and even GitHub repositories, piled all available information together and came up with the answers. Mind you, this applies only to apps using AdMob only – if you use anything else from a third party or even if you collect data for yourself, you need to take that into consideration.
This is how we filled out the form for our apps using AdMob that Google Play accepted.
Question1: Does your app collect or share any of the required user data types?
Yes
Obviously yes, since you are using Google AdMob and otherwise you wouldn’t have to do this.
Question 2: Is all of the user data collected by your app encrypted in transit?
Yes
Thankfully yes, all data collected by Google (and not just AdMob) is encrypted.
Question 3: Do you provide a way for users to request that their data is deleted?
Yes
We really weren’t sure about this one since we didn’t build any opt out options in our apps because we personally don’t collect anything. But luckily AdMob takes care of that one by itself and even if it wouldn’t you can still opt out in your Google account settings. In case you didn’t know, to opt out of ads personalization on your Android phone go to Settings -> Google -> Ads (in the services on this device section) and turn on the Opt out option.
Ok, moving on with the form. This first section was the easy part.
In the second part you need to disclose information regarding all the user data types that are collected.
In the Location section that is at the top, choose Approximate location. For purposes of targeted advertising, AdMob wants to know the approximate location of the user’s device.
The rest of the list looks very daunting and it honestly gave half of our team a few nightmares. But reading through AdMob policies and help sections we found out that AdMob doesn’t really collect a whole lot of data. Sure, overall Google collects a bunch of data about their users, but it uses different services to do that.
Which means you get to scroll down towards the bottom until you find the App info and performance section. There you click on all three options: Crash logs, Diagnostics and Other app performance data. The Other app performance data includes but is not limited to “app launch time, hang rate, and energy usage,” as stated in Prepare for Google Play’s data disclosure requirements.
And, last but not least, you need to tick off the Device or other identifiers because that is collected by AdMob as well.
Then simply click Next in the bottom right corner and you will continue to the next step. This is the last one and ever so much fun! You get to provide more details for each of the data types you just selected.
It’s really not as horrible as it looks because mostly all your answers will be the same. So, click Start for each data type, starting with Approximate Location and get it done with. The first part of the pop up (yes, we progressed to actual pop ups now) will look like this:
The data is Shared because the app collects it for AdMob only – you don’t have anything to do with it.
The data is NOT processed ephemerally because it’s not only stored in memory for a brief time. It is stored, filtered and analyzed six ways to Sunday. After all, AdMob can’t match ads to users if it doesn’t know the users.
And yes, data collection is required. If your users agree to receive personalized ads then they can’t choose for their data not to be collected. Now you will ask what about users who don’t agree. Of course, their data isn’t collected but the instructions from Google are to describe the sum of your app’s data collection and sharing. That means if data collection is required even for one single user, then you must choose the required option.
In the second part of this pop up you need to select all the reasons a specific data type is shared. Again, this will be very similar for all data types you have selected. For the Approximate Location type you need to select Analytics, Fraud prevention, security and compliance and Advertising or marketing, which means it will look like this:
Then click Save in the bottom right corner of the pop up and move on to the next data type.
For Crash logs the first part is identical as stated above for Approximate Location and in the second part you need to select App functionality.
For Diagnostics the first part is again the same and in the second part select Advertising or marketing.
Other app performance data, repeat the first part, then select Analytics and Advertising or marketing.
And the last data type you now have left is Device or other identifiers. The first part is again the same as all others and in the second part select Analytics and Advertising or marketing.
Click the blue Save button on the bottom to continue to the next step and you will see the preview of Shared data as it will be visible to users in the Google Play store. It should look like this:
The only difference is, you will be linking your own Privacy policy – which you have probably already done since it’s been mandatory for quite a while now. Just in case you haven’t, go to App content (same as for the Data safety section you just completed) and select Privacy Policy.
Don’t forget to click the final Save button and you’re all done. Now all you have to do is wait for the review process to complete and your store listing will be updated.
In our case, the review process took about 6 hours for half of our apps and about 12 hours for the other half.
Remember, once you complete the form for one app, you can export it to CSV, save it and then import to it all your other apps. The export and import links can be found on the top right part of the form.
That’s it! Happy publishing 🙂