Apple Regulatory Requests
A very quick 2020 update.
Given the recent interest in Apple Regulatory and legal requests, the FBI again asking Apple to unlock it's phones, I thought it a useful reminder to everyone that Apple is construed as a law abiding citizen just like everyone else. As such it is absolutely not a suprise that the FBI make such requests and would not suprise me if these types of request are regularly fulfilled where possible.
As you can see, from my article below at the start of 2019 and the above quickly updated chart, these requests are rising and rising.. I've projected 2019 as only H1 is available, but it's already way over half of the 2018 numbers.... and if you look closely at the raw numbers, you will also see that fulfilment of such requests is rising.
Compliance with the law where it is required is NOT a suprise at all and why do we focus on Apple, who are relatively transparent about these things... compared to say Amazon, Google or Microsoft?
Fully updated article to follow over the weekend, split by population as below. Source data can be downloaded here: Data Set
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An Apple ID owner can request a download of the majority of data held by Apple in relation to that ID. Take a look here: Apple ID Privacy
While doing that for my own Apple ID, I took a look at some of the other information published by Apple. In their twice yearly report on requests from authorities and other parties, Apple does a better job than most in sharing information on the requests they receive and the numbers fulfilled. Owing to some rules and regulations and the sensitivity of the data, it's obviously broadly categorised and summarised.
Apple's general statement on this is: "We believe our customers have a right to understand how their personal data is managed and protected. Apple’s Transparency Report provides information regarding government requests for customer data" - Apple Transparency
Obviously it's not my intention to pass judgement on this information, but being the geek I am, I feel I need to play around with the data published and summarise it in a basic manner. It's can't be helped right?
It's important to note their straightforward explanations of the categories and limitations (here).
Volume
At a very high level, let's look at the volume of requests over time:
I won't pass judgement here other than to say there would be a number of factors influencing the rise in numbers over this period. For one, Apple only started collating and publishing the numbers a few years back. Secondly, new countries would have been added over time. But there's definitively a general uptick...
Fulfilment
Now looking at the number of these requests that were satisfied across the countries and years published. There's an obvious general increase in the percentage of requests fulfilled. So, more requests and generically more of those requests being fulfilled by Apple. Some countries are reported in one year and not the next. The numbers I have used here are simple averages of the fulfilment percentages across all countries, years and categories.
Generally though, there's a rise in successful or partially successful requests (for account information, device requests, Financial identifiers etc etc).
By Country
Taking this one step further: by country.
This is a little surprising. The volume of requests reported (of all types over all years where figures are available) I expected the USA to figure top.
Please note, this is pseudo-scienctific and ranked on a ratio of the volume of requests multiplied by the percentage fulfilled. That gives an indication of activity (requested, fulfilled) for the Top 20. Germany features top, the US just behind. Switzerland figures in the Top 20 also.
Population
Adjusting the numbers of requests for all types of information, per 100,000 population of a country (based off information available at The World Bank - Data Bank), over the entire available time period - we can see that Singapore had the highest number of requests per head significantly. Germany is in second and the UK and US, quite a way down the Top 20.
In summary though, the article is to demonstrate that there is information being published by Apple and although slightly limited in the 30 mins I spent writing this, I hope to encourage others to take a look and play around with the information for their own countries. Perhaps they can also cast an opinion on the following questions I have:
- Why is there a continuous uptick? There are countries added, removed, an increased awareness of the necessity of requesting this type of information and an improved and streamlines way for authorities to request it. Any other thoughts?
- Is there a better way to normalise and present this information? Bear in mind I don't have any particular point to make, other than the information is available..
- Is there also a rise in compliance of Apple in fulfilment of these requests? I don't have the patience to be rigorous about it, I'm not a statistician by trade. But can we assume that?
- Is data available for other companies? Google, Microsoft, Amazon maybe?
- Any other interesting information that can be gleaned from this insightful data?
Have a play around with the full data set here: Data Set
Disclaimer: This is all my own opinion and experience (or the opinon and experience of any contributor) and isn't reflective of the views of my (or their) current or previous employers. I love iPhones. I would relish the opportunity to rewind time and study law. Seriously.
About Martin: Over the past 17 years I've worked with Chief Legal Officers, General Counsel, Compliance Professionals and ‘Big Law’ firms globally, to provide, create and implement systems and processes that reduce the likelihood of failure during a crisis.