Actions Speak Louder than Words: Entity-Sensitive Privacy Policy and Data Flow Analysis with PoliCheck

Identifying privacy-sensitive data leaks by mobile applications has been a topic of great research interest for the past decade. Technically, such data flows are not “leaks” if they are disclosed in a privacy policy. To address this limitation in automated analysis, recent work has combined program analysis of applications with analysis of privacy policies to determine the flow-to-policy consistency, and hence violations thereof. However, this prior work has a fundamental weakness: it does not differentiate the entity (e.g., first-party vs. third-party) receiving the privacy-sensitive data. In this paper, we propose POLICHECK, which formalizes and implements an entity-sensitive flow-to-policy consistency model. We use POLICHECK to study 13,796 applications and their privacy policies and find that up to 42.4% of applications either incorrectly disclose or omit disclosing their privacy-sensitive data flows. Our results also demonstrate the significance of considering entities: without considering entity, prior approaches would falsely classify up to 38.4% of applications as having privacy-sensitive data flows consistent with their privacy policies. These false classifications include data flows to third-parties that are omitted (e.g., the policy states only the first-party collects the data type), incorrect (e.g., the policy states the third-party does not collect the data type), and ambiguous (e.g., the policy has conflicting statements about the data type collection). By defining a novel automated, entity-sensitive flow-to-policy consistency analysis, POLICHECK provides the highest-precision method to date to determine if applications properly disclose their privacy-sensitive behaviors.