Privacy policies of health apps and websites should be (re-)written and (re-)designed to promote cognitive accessibility
Guidance
Policy-makers and developers of apps and websites, particularly those for people with cognitive impairment or dementia, should review and improve the cognitive accessibility of privacy policies associated with apps and websites. Privacy information should be available in the official language of each country in which the app or website is available. Navigation to information should be promoted by simple, attention-focusing user interface design. Length and linguistic complexity of information in the privacy policy should be limited, or the information should be summarized.
Explanation and Examples
Cognitive accessibility conceptualizes the extent to which digital services are simple, consistent, clear, multimodal, error-tolerant, and attention-focusing to use, taking into account all users.
Online data privacy is an important legal and ethical issue, and an important concern of many (potential) app-users, which may impact on their adoption of digital tools and services. The European General Data Protection Regulation (GDPR) protects people’s right to access information about how their data is processed, so that they can make informed choices, but there are concerns that many privacy policies are too long, too complex and sometimes not even available. This may reduce trust in digital tools, presenting a barrier to adoption.
A cross-sectional study found that, in the Netherlands, Sweden and the UK:
- Most health and wellness apps sampled outside the UK did not have a privacy policy available in the official language of the user’s country
- Almost no privacy policies met reading level benchmarks, meaning the language was too complex for the average native speaker to understand.
- The time that it would take the average adult native speaker to read each privacy policy was 10 minutes (websites) to 12 minutes (apps).
Recommendations to improve the cognitive accessibility of online privacy information have been made. An example of a privacy policy designed largely in line with these recommendations is the privacy policy of the FindMyApps project, which can be found on the project website: https://findmyapps.onderzoek.io/cognitively-accessible-privacy-information
Type of evidence
Cross-sectional scoping research comparing observable properties (relating to availability, ease of navigation and readability) of privacy policies of the top health and fitness apps in the apps stores run by Apple and Google, with a purposively selected sample of websites.
References
Neal, D., Gaber, S., Joddrell, P., Brorsson, A., Dijkstra, K., & Dröes, R. M. (2023). Read and accepted? Scoping the cognitive accessibility of privacy policies of health apps and websites in three European countries. Digital health, 9, 20552076231152162.
https://doi.org/10.1177/20552076231152162