With two and a half months left before the end of the year, much is still unknown about Apple’s new policies around tracking, which are expected to go into effect in “early 2021”. And ever since the implementation delay announcement in early September, the relevant page on Apple’s developer website said to expect more details in the fall.
This week, as Apple announced new iPhones, some clarity emerged about the tracking policies as well. A recent update to the “User Privacy and Data Use” page added a Frequently Asked Questions section with some extra content related to the change.
More than the sum of its parts, the FAQ reinforces the spirit of Apple’s policy changes. What’s happening isn’t strictly about IDFA collection, nor is it about SKAdNetwork — the maker of iOS wants tracking transparency for its users in every data transaction conducted via their operating system.
Apple spells it out in one of the answers, saying, “Developers must get permission via the app tracking transparency prompt for data collected in the app and used for tracking. Data collected separately, outside of the app, and not related to the app is not in scope.”
For example, device fingerprinting is expressly forbidden. It also means that app developers are responsible for every single line of code in their app, even when integrating a 3rd party SDK. Developers won’t be able to plead ignorance of data collection in SDKs and should make sure they know exactly what their partners are collecting. This also includes single sign-on (SSO) SDKs, which are explicitly mentioned.
And lest anyone think that identifiers such as email or phone number are ok, Apple spells it out yet again: tracking users by any identifier in iOS for advertising purposes would require their permission.
Readiness Is Everything
In our post-IDFA readiness webinar, we have said that the next few months are crucial for marketers who rely on iOS, and presented a dual-prong approach marketers should be exploring: SKAdNetwork testing and a product-centric exploration of user consent scenarios and flows.
The new clarifications make it even more apparent — user-level signals are on very thin ice right now. This, in turn, makes the task of establishing a testing pipeline for SKAdNetwork as soon as possible much more important. You won’t have much time to see SKAdNetwork data alongside deterministic data, and any insights you can glean from this period will be immensely valuable.
The FAQ also makes it clear that there are conversations that should start happening right now. Conversations with your partners to see what their strategy will be, with SDK providers to ensure they’re not increasing your exposure, and with your product teams to get ready for the eventuality of IDFA collection being worth the effort. If we’re in early 2021 and discover that users are willing to opt into tracking, it will be the apps that explain this tracking the best that will see the best results.