Apple's In-App Account Deletion Requirement is Coming (but Not Quite Yet)
Last year, Apple announced that - starting January 31, 2022 - it would require apps distributed through its app store that offer users the in-app ability to create an account to likewise offer the ability to initiate the deletion of that account from within the app. (The requirement appeared without much fanfare, initially in a June update to the App Store Review Guidelines and then with a modest publicity push from Apple in October.)
Aside from laying out the basic premise, Apple has offered little guidance on the requirements or practicalities of this edict. For example, it had been unclear whether compliance required merely deleting the user’s account or whether Apple intended this to be a method to submit a request for the deletion of the subject’s personal data a la the CCPA.
While much remains unclear about this, Apple offered two helpful tidbits this past weekend. First, it extended the compliance deadline to June 30, 2022, providing some much-needed relief to app developers who had been struggling to unpack the not-that-latent complexities of this requirement (including how to reconcile it with the CCPA’s existing-but-more-nuanced deletion rights and what to do about deletion requests from active subscribers). Second, it clarified that this deletion option extends beyond the account itself. Per Apple: “People should be able to delete the account along with their personal data.”
Much work - of both the analyzing/divining and the building kind - remains to be done. For app operators who need to have a deletion feature operational before submitting any app for review come July, the time to dive in fully is right now.