According with the GDPR the essential
information should be clear and made available to the
user, followed by options for the user to specify what
personal data can or cannot be processed, preferably
with icons or pictures. Clearly, this situation is not
happening at the moment. These are basic privacy
mandatory requirements that should be made
available for every type of app, much so for people
with dementia, who need more care and clarity when
exposed to this technology.
Another critical issue is that one third of the
analysed apps do not inform the user about what type
of data and features the app will be accessing when
running while more than a third request some type of
personal data to be installed to fully function. This
disparity of procedures is not helpful and, many
times, there is no need to request personal data unless
the apps have more complete features such as health
advisors, health journals or functionalities that allow
data to be shared, for instance, with health
professionals. However, apps to train brain activity
and cognition, even if they follow users’ progress,
they commonly do not need to require personal data,
nor even data from special categories such as health
related data (as shown in Table 1, for almost all apps
this GDPR key requirement is not applicable). Still, if
they do, they need to make users well aware of what
data are being processed, how and what security
measures are in place and consent must be provided
at all times before that processing starts. Contrary to
this, most analysed apps do not provide the
opportunity to give consent to the various parameters.
Further, in the cases where this is possible (11%),
there is no liberty for the users to change their mind
and revoke that previously given consent.
As to the right to be forgotten, even when the user
creates an account and introduces personal data, a
small number of cases allow users to delete their
profile entirely, again, not in conformance with
GDPR.
Limitations. During this research the authors could
not find information and studies about the impact of
the new GDPR on the development of mHealth apps
and more specifically in cases of apps for people with
dementia, to be able to compare with.
Our sample is very small because, as a first study
in this area, we decided to focus on a restrict group of
apps that specified in their description that they were
designed to improve the cognitive function of people
with Alzheimer's disease and dementia. Due to time
constraints only one researcher did the selection and
revision process. However, used methods can be re-
used/improved by other researchers and re-applied
for a larger sample. Also, we have just experimented
and tested apps for Android, making exclusive
applications for iOS system excluded in our study.
6 CONCLUSION
Despite all the advantages that apps seem to offer to
keep the brain active and help people with AD and
dementia to better cope with their disease, there are
several security and privacy concerns that are still not
addressed. This is particular important for this group
of people as they can potentially be more vulnerable
and less aware to online dangers and privacy breaches
as they may lack the cognitive capacity to interpret
and fully realize the problems.
Through this study we found that most available
analysed apps do not provide any information about
how they process and treat personal data or, if they
do, it is not done in a very clear manner. Furthermore,
most of the key requirements mandated by GDPR are
still not implemented in the available apps and so
these do not comply with regulation to ensure privacy
and security in the interactions between users and
mobile apps, for European citizens.
This work intends to bring awareness to this issue
to both researchers and developers, especially in the
area of healthcare and mental health. Further, it aims
to give some recommendations for future research,
e.g., (1) structured guidelines or principles should be
made available online for all mobile app developers
during the app creation process, to ensure
transparency and to be as much as possible GDPR
compliant, (2) the generalized use of simple, clear,
transparent and understandable Privacy Policy,
always available through a button in the menu
configurations or even in another visible part of the
app, (3) mandatory use of explicit consent, thus when
a user is making a registration on a mobile app, s/he
should be asked to opt-in to have their data collected
or receive communications (emails or notifications)
and this could be done through a consent screen on
the app launch. This screen should also show
information about what user´s data will be collected
and how they are going to be processed, (4) available
functionality where users can ask for their data to be
removed or can request their data to be deleted and
have an opt-out of communications/notifications, (5)
strong encryption algorithms of personal data by
default, (6) every mobile app must include contact
information of the business or app developer, so that
users can contact them and have a quicker and clearer
support, and, most importantly, (7) the existence of
app regulations made by credible entities related to