Mobile applications and 152-FZ (“On the protection of personal data”)?

Question

Mobile development

Please tell us how you achieve compliance of the mobile application developed by you with the Federal Law No. 152 “On the Protection of Personal Data”. A simple example is home delivery. To order, you need to get the information “Name”, “Phone”, “Delivery address”, and this is essentially personal data. Has anyone found out the position of Roskomnadzor on this matter? Or do you indicate during registration that the client consents to the receipt, processing and storage of personal data? I have not seen this in mobile applications.

Answer 1

Remove the name and you'll be fine (you can just ask for the name during the order confirmation call). Phone and address are not personal data, because they do not indicate a specific person.
Regarding consent, it’s all bullshit if the application does not pass certification, but wants to submit this data under the sauce of the public (as, for example, in a telephone directory). Indeed, this can be done, but this requires written permission (a tick in the interface will not work) - are you ready to take a signature from each client?