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Privacy Evaluation for WhatsApp Messenger

Last updated January 17, 2020

Overview

WhatsApp is a general-purpose messaging app. If you are an existing user, you can choose not to have your WhatsApp account information shared with Facebook to improve your Facebook ads and products experiences. Personal Information collected includes the messages themselves, including chats, photos, videos, voice messages, files, and share location information. WhatsApp's policy says that they don’t store user messages once they’ve been delivered, and that when they are end-to-end encrypted, WhatsApp and third parties can’t read the user messages. Children under 13 are not permitted to use the app at all, according to its policy.

WhatsApp can be accessed through its website, and is available for download at the iOS App Store and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on WhatsApp’s website, iOS App Store and the Google Play Store. Additionally, other policies used for this evaluation include: Privacy Shield, Cookie and Payments Policies. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Whatsapp is a messaging service and users provide the service with the phone numbers of WhatsApp users and your other contacts in the user's mobile phone address book on a regular basis. If you are an existing user, you can choose not to have your WhatsApp account information shared with Facebook to improve your Facebook ads and products experiences. The app does not include any content moderation or safety protocols, in fact, the policy notes that user messages are not able to be read by WhatsApp. Their policy explains that they have built privacy, end-to-end encryption, and other security features into WhatsApp.

Privacy

WhatsApp's policy says that they don’t store your messages once they’ve been delivered, and that when the messages are end-to-end encrypted, they and third parties can’t read them. Personal Information collected includes the messages themselves, including chats, photos, videos, voice messages, files, and share location information. Phone numbers and some device information are part of the non-personal information collected. Their policy notes that they may use cookies to remember user choices, such as language preferences, and otherwise to customize our Services for the user. They state that they will collect information about user online and status message changes on WhatsApp Services, such as whether the user is online, when the user last used the Services (the “last seen status”), and when the user last updated their status message. WhatsApp is part of the Facebook family and partners with banks and other third party services to offer user services on their app.

Security

WhatsApp's policy explains that it uses reasonable security, and it appears that an account is required, although passwords are not mentioned. When a user registers to use Payments, they provide their bank’s name and confirm the bank account for use with Payments. The policy explains that WhatsApp messages for the users, and WhatsApp can’t read the messages. Their policy adds that they built privacy, end-to-end encryption, and other security features into WhatsApp. WhatsApp's policy says that they don’t store user messages once they’ve been delivered, and that when they are end-to-end encrypted, WhatsApp and third parties can’t read the user messages. There's no discussion of how or whether WhatsApp will notify users of a data breach.

Compliance

WhatsApp is a general-use app, and its policy does not mention students, teachers, or an educational purpose. Children under 13 are not permitted to use the app at all, according to its policy. In some circumstances Whats App's policy explains, WhatsApp will work with its Partners to provide individuals access to personal data about them that WhatsApp holds on behalf of its Partners. Also, WhatsApp indicates that it will also take reasonable steps to enable individuals, either directly or in connection with the Partners, to correct, amend, or delete personal data that is demonstrated to be inaccurate. There's no mention of whether they will delete child personal information, or any discussion of COPPA, FERPA, beyond the contractual consent required of parents to let children under the legal age of contracting consent (usually 18) to use the service.

Data Collection
SCORE: 50%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Non-personally identifiable information is collected.
  • Opt-in consent is not requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 90%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • The categories of third parties that receive personal information are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • The roles of third-party service providers are indicated.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 40%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Unclear whether third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 85%

What rights do I have to the data?

  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 20%

Is the data sold?

  • Unclear whether data are sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • User information can be transferred to a third party.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 55%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Profile information is not shared for social interactions.
  • Personal information is not displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is not reviewed, screened, or monitored by the vendor.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 65%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are not displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 35%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is not collected online.
  • Unclear whether intended for parents or guardians.
  • Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Parental consent is not required.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 10%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Product is not primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.