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Regulators, Mount Up! Analysis of Privacy Policies for Mobile Money Services Jasmine Bowers, Bradley Reaves, Imani N. Sherman, Patrick Traynor, and Kevin Butler, University of Florida https://www.usenix.org/conference/soups2017/technical-sessions/presentation/bowers This paper is included in the Proceedings of the Thirteenth Symposium on Usable Privacy and Security (SOUPS 2017). July 12–14, 2017 • Santa Clara, CA, USA ISBN 978-1-931971-39-3 Open access to the Proceedings of the Thirteenth Symposium on Usable Privacy and Security is sponsored by USENIX. Regulators, Mount Up! Analysis of Privacy Policies for Mobile Money Services Jasmine Bowers, Bradley Reaves, Imani Sherman, Patrick Traynor and Kevin Butler {jdbowers, reaves, shermani, traynor, butler}@ufl.edu Florida Institute for Cybersecurity (FICS) Research University of Florida Gainesville, Florida ABSTRACT networks, often limiting economic expansion and bur- Emerging digital financial services use mobile phones dening the majority of people around the world with the to provide access to populations traditionally excluded physical risks and challenges associated with managing from the global economy. These \mobile money" ser- currency (e.g., theft, difficulty performing transactions, vices have proven extremely successful in their first ten etc). years of deployment, and provide a powerful means of \Mobile money" services attempt to address this prob- raising people out of poverty. Such services have ac- lem by making phones into payment platforms. Two cess to a wealth of customer information, potentially arbitrary parties, whether in person or at a great dis- including entire purchase histories, geolocation, and so- tance, can easily transfer money between each other cial network information. In this paper, we perform the instantaneously. Technologically, this is implemented first study of privacy policies in mobile money services, by various means: built-in \apps" for feature phones, evaluating policies from 54 services and comparing them simple text messages exchanged with the mobile money to 50 policies from traditional financial institutions. Be- system, and in some limited cases smart phone apps. cause mobile money services are developed under a wide While conceptually simple, this technology has proven range of regulatory environments, we compare policies transformative. First, citizens incapable of visiting tra- to the industry standard (the GSMA's Mobile Privacy ditional banking services or maintaining relatively high Principles) and to a traditional national standard (the minimum balances can participate in such services and FDIC's Privacy Rule Handbook). Our analysis shows pay only minimal transaction fees. Second, because vir- that almost half (44%) of these mobile money services tually anyone with a phone can participate, it is sim- do not have any privacy policy whatsoever. Of the ser- ple for nearly every person and vendor in a country vices that do have privacy policies, roughly one-third to be enrolled in the service. Finally, many such ser- (33%) fail to provide them in either of the two most vices are using information gathered on transactions to common languages of their market. Furthermore, 50% generate non-traditional creditworthiness measurements of these policies do not ever identify to the user what and insurance profiles, further enabling those in devel- data is actually being collected and stored. Finally, we oping economies to gain access to investments that have find that where policies do exist, they are often incom- proven essential for raising people out of poverty [39]. plete and difficult to read by their target customers. These findings show that more work is needed to protect The implications of collecting and managing customer consumer privacy within these mobile money services. data in this environment are more risky than in tradi- tional financial services. Specifically, because true peer- 1. INTRODUCTION to-peer payment is enabled by mobile money services, Cashless systems underpin our modern economy and the they learn both their customers' entire financial history developed world now relies heavily on a massive digital and their social network. Moreover, many services also infrastructure capable of moving money across the globe collect supplementary information including geographic without delay. However, many parts of the world re- location and the names of other applications installed main unable to easily access these traditional financial on a device. The need for strong, clearly written pri- vacy policies is therefore evident, and has been strongly supported by the industry group (i.e., the GSMA) since 2011 [43]. However, how the industry has adopted such regulation has not previously been explored. In this paper, we perform the first independent anal- ysis of privacy policies for the mobile money industry. Copyright is held by the author/owner. Permission to make digital or hard copies of all or part of this work for personal or classroom use is granted While work has been done to evaluate privacy policies without fee. of traditional financial services in the past [13, 19, 37], Symposium on Usable Privacy and Security (SOUPS) 2017, July 12–14, our work is different for a number of reasons. First, 2017, Santa Clara, California. USENIX Association Thirteenth Symposium on Usable Privacy and Security 97 ours is the first work to evaluate mobile money services, The remainder of the paper is organized as follows: Sec- which are generally run by non-traditional financial enti- tion 2 discusses related research; Section 3 provides back- ties (e.g., telecommunications providers) and are there- ground on mobile money; Section 4 describes our method- fore not subject to the same kinds of regulations as the ology; Section 5 provides our results; Section 6 further conventional banking industry. Second, we are not at- discusses the implications of these results, and Section 7 tempting to measure the \goodness" of the standards provides concluding remarks. for the industry; rather, our work seeks to measure mo- bile money services against standards that are already 2. RELATED WORK in place. We believe this is critical as it measures the Mobile money services have had enormous positive im- health of consumer privacy within the industry as expec- pact in enabling financial inclusion in the developing tations are currently set. Arguments for greater protec- world. However, the security provided by such services tions beyond what is suggested can always be made. Fi- has recently come into question. First generation ser- nally, mobile money services served approximately 411 vices, which rely on SMS or USSD channels in 2G net- million customers in 2015, and recent moves including works, are inherently insecure due to the use of weak (or demonetization in India put the industry's population no) ciphers on the air interface and the lack of strong base in the billions [38]. As these customers often rep- end-to-end encryption [10,28]. Unfortunately, Reaves et resent many of the world's most financially vulnerable, al. [31] demonstrated systemic problems in smart phone it is critical for the privacy community to ensure that apps throughout the ecosystem, including poor configu- they are adequately protected. ration, failure to properly authenticate certificates and in some cases, a complete lack of any protections. More- We make the following contributions: over, most developers failed to improve the security of Compare Policies Against GSMA and FDIC Rec- their applications over a year later in spite of receiv- ommendations: Given that mobile money services ing detailed vulnerability reports [30]. Castle et al. in- are deployed across a wide range of regulatory environ- terviewed developers to understand the cause of such ments, performance against a single national standard weaknesses, learning that many developers had diffi- for privacy policies would be incomplete. Accordingly, culty properly using security libraries [11]. we determine how these services conform to the mo- Creating \good" privacy policies is a challenge in and of bile money industry (i.e., the GSMA) and widely used itself. Entities handling user data must strike a care- government (i.e., the US Federal Deposit Insurance Cor- ful balance between both comprehension and compre- poration (FDIC)) recommendations for communicating hensiveness. A number of researchers [21, 32, 36] pro- privacy policies. Our analysis shows that mobile money vide guidelines for policy creation. McDonald and Cra- services lag significantly behind traditional financial in- nor [25] argued that a singular focus on coverage repre- stitutions, with 44% having no available policy. More- sents a significant expense to users and determined that over, where policies are available, their coverage of crit- it would take users over 200 hours per year to read the ical topics is often limited. All but one service fail to policy of each website visited. Other researchers have meet either standard. attempted to achieve such balance, using techniques Measure Readability: Literacy rates are often lower such as bulleted lists [17], privacy \nutrition labels" [22], in the developing world. To measure whether or not and natural language processing for minimization [46]. privacy policies adjust for this difference, we use multi- Unfortunately, while such techniques appear to improve ple tests of readability from the linguistics community readability, only one (Federal Reserve privacy notice to compare traditional financial and mobile money offer- template)

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