A policy primer for NET303

By Alyssa Potter

23snaps logo: 23snaps, n.d.

What is it?

“23snaps is a private photo sharing app designed by

parents, for parents. 23snaps gives you a completely safe and

secure way to record the special moments in your

child’s life and share them with your loved

ones, wherever they may be in the world.” (23snaps, n.d.d)

23snaps screenshot: 23snaps, 2015b

In other words, you can share images, videos, stories and other personal details about your child and family life by inviting those closest to you to view them through 23snaps without broadcasting it all over social media.

So you can stop annoying your friends with your ‘sharenting’.

A social media phenomenon that happens when one becomes a parent and constantly shares personal information about their child on social media, information that the child might be embarrassed about later in life.

University of Michigan Health System, 2015

#babysfirstphotoshoot #cutestbabyever

Or exposing your child to the potential of digital kidnapping.

Willets, n.d.; University of Michigan Health System, 2015

A scary new form of identity theft where someone claims that your child is their own through photos you have posted on social networking sites.

BUT ENOUGH OF THE MARKETING SPIN...

THE REAL QUESTION IS DO THE TERMS AND CONDITIONS REFLECT 23SNAPS MARKETING OF BEING ‘SAFE AND SECURE’?

AND HOW ARE YOUR PERSONAL DETAILS, PHOTOS AND VIDEOS PROTECTED?

The Promise

“We promise that we will never share your personal information, photos, videos or updates without your consent.” (23snaps, n.d.c)

The Reality

Separate to but forming part of the Terms and Conditions is the Privacy Policy that sets out users’ privacy rights and data collection.

The Reality

It’s important to note that this can be changed at any time and posted to the website or on the app. However it is not clear how users are notified.

The Reality

As a United Kingdom based company, it complies with the Data Protection Act 1998.

“An Act to make new provision for the regulation of the processing of information relating to individuals, including the obtaining, holding, use or disclosure of such information.”

This Act gives you the power to access any information held about you.

The Reality

23snaps collects: – your full name and email

address OR login details for your Facebook account

– location/GPS coordinates

– IP address

– device information (browser type, device identifier)

– your activity on the App

The Reality

What happens to that information? – data is aggregated to show and analyse users’

actions, usage and patterns to help personalise and improve customer experience

– However they can track your personal usage

The Reality

What happens to that information? – ability to send you updates on the content or

functionality of the App

– notify you about

services changes

The Reality

What happens to that information? – add location to your posts

– connect with and notify friends and family about updated content

The Reality

Good news for users is that data is not shared with third parties for marketing purposes unless your permission has been received.

The Reality

However aggregated data may be shared for analysis.

The Reality

And personal information can be used to comply with the law or to enforce any of their policies.

The Reality

You can opt of data sharing by contacting them or by amending your privacy settings in the app.

This gives you control over what is shared outside of 23snaps.

WHILE PERSONAL INFORMATION IS DEALT WITH, THERE IS NOT A LOT OF DETAIL ABOUT HOW IT CAN USE YOUR PHOTOS, VIDEOS OR UPDATES.

When it comes to content

The Terms and Conditions grant 23snaps “a non-exclusive, worldwide, perpetual, irrevocable licence to use your Content to the extent necessary for 23snaps to provide the Service” (23snaps, n.d.a). “Nothing in these Terms will serve to transfer ownership of the Content or the Intellectual Property rights therein to 23snaps” (23snaps, n.d.a).

This means that they are the only ones that can use your content.

And you remain the owner of the Content

And they can only use it to provide the Service

It also explicitly states that you cannot use another user’s content unless you get their permission.

This protects you from others in your circle sharing those personal details of your child’s life.

If you decide you no longer want to use the service, you can delete the account.

Along with all your data (which will only be held in backup as required by law).

SO WHAT ARE YOUR RESPONSIBILITIES?

Your Responsibilities

• You agree that you are responsible for all your activities on the app.

• You agree that the Content you upload is not illegal, offensive or inappropriate.

• You agree that you are uploading Content that you have the copyright to.

• You are over 18 years of age. • You are the legal guardian of the child/children

that you connect to the account.

If you breach any of those conditions, 23snaps can remove any of your content.

It can also terminate the App and delete the content.

The good news is that you will have at least 30 days to retrieve your content.

BUT WHAT HAPPENS IF THE CONTENT OF 23SNAPS IS ILLEGALLY ACCESSED? AND ITS CONTENTS MADE PUBLIC?

The Promise

“Your content is all stored in a highly secure online environment – the same type of system used to securely process credit card details.” (23snaps, n.d.c)

The Reality

There is no mention about the security and storage of your content in the Terms and Conditions or the Privacy Policy.

The Reality

Or what happens if your content is accessed illegally or hacked.

Or if your content is distributed illegally.

The Reality

This is concerning as there are no guidelines about their responsibilities for ensuring the security of your content.

The Reality

The whole point of the App is for the content to be private.

Without any clear guidelines in the Terms and Conditions, you have to hope that it will stay that way (without knowing how it is).

“IT IS OUR ABILITY TO CONTROL WHO HAS ACCESS TO US AND WHO KNOW WHAT ABOUT US, THAT ALLOWS US TO SUSTAIN THE VARIETY OF RELATIONSHIPS WE HAVE WITH OTHERS.” Introna, 1997

SO THIS BRINGS US TO OUR NEXT POINT...

HOW DO THEY KNOW YOU ARE WHO YOU SAY YOU ARE?

How do they know it’s really you?

23snaps states

“By registering your details and setting up an Account you consent to 23snaps conducting verification and security procedures in respect of the information provided by you online.” (23snaps, n.d.a)

How do they know it’s really you?

Both avenues to sign up for an account allow for some identity verification.

#1 – First name, last name and an email address

#2 – Connect with Facebook

How do they know it’s really you?

If you register an account with an email address, they verify it through a verification email.

How do they know it’s really you?

If you register your account by connecting with Facebook, they are relying on Facebook’s identity check

How do they know it’s really you?

By registering with your Facebook account, this allows 23snaps access to your Facebook account.

Including your login details.

And to store that information.

How do they know it’s really you?

However if you are insistent on registering with phony details, there is not much to stop you.

SO WHAT’S THE LONG AND SHORT OF IT?

23snaps provides users with a private space to upload content and share it with who they choose.

They are explicit with what information they collect and what they use it for.

They allow you to control whether your information is shared for marketing purposes.

They are only allowed to use your content in relation to providing the service.

You are protected from other users using your content without your consent.

You are responsible for your content and your behaviour.

They provide themselves with the ability to confirm your identity.

Sadly there is no clear outline as to how the security of the site is handled.

Or what would happen if there was a breach.

Which is key considering this App is all about privacy of your family’s life.

So all your content is protected from being used by 23snaps for any purpose.

But you still need to be careful with what you post, as you never know if the content is safe from being illegally accessed.

So how does it rate?

Using the Privacy Protection Scale introduced by Goettke and Christiana (2007), 23snaps would be rated a Tier Five (5) website.

“websites [that] completely ensure the privacy protection of all users. “ (Goettke & Christiana, 2007, p.3)

References 23snaps. (n.d.a). TERMS & CONDITIONS. Retrieved 17 October, 2015, from

https://www.23snaps.com/terms 23snaps. (n.d.b). Homepage. Retrieved 17 October, 2015, from https://www.23snaps.com/ 23snaps. (n.d.c). Privacy. Retrieved 17 October, 2015, from https://www.23snaps.com/privacy 23snaps. (n.d.d) OUR STORY. Retrieved 17 October, 2015 from https://www.23snaps.com/about 23snaps. (2015a). 23snaps logo [Image]. Retrieved from https://23snaps.zendesk.com/hc/en-us 23snaps. (2015b). 23snaps homepage [screenshot]. Retrieved from https://www.23snaps.com/ 23snaps. (2015c). 23snaps Sign Up [screenshot]. Retrieved from

https://www.23snaps.com/account/register

References Goettke, R. & Christiana, J. (2007). Privacy and Online Social Networking Websites. Computer

Science 199r: Special Topics in Computer Science Computation and Society: Privacy and Technology. Retrieved from http://www.eecs.harvard.edu/cs199r/fp/RichJoe.pdf

Introna, L. D. (1997). Privacy and the computer: why we need privacy in the information society.

Metaphilosophy, 28(3), 259-275. Retrieved from http://onlinelibrary.wiley.com.dbgw.lis.curtin.edu.au

University of Michigan Health System; 'Sharenting' trends: Do parents share too much about kids on

social media? (2015). Pediatrics Week, 11. Retrieved from http://search.proquest.com.dbgw.lis.curtin.edu.au

Willets, M. (n.d.) Posting Your Kids' Pics on Facebook May Put Them at Risk for Digital Kidnapping.

Parenting. Retrieved from http://www.parenting.com

Images All images are under a Creative Commons CC0 licence. Retrieved from https://www.pexels.com/

and https://pixabay.com/