A data safety declaration is a developer attestation about how an app and its included components collect, share, and protect user data. It requires the publisher to account for third-party SDK behavior as well as first-party code. The declaration is only as accurate as the team’s visibility into integrated dependencies.
Expanded Definition
A data safety declaration is a published statement that describes how a mobile or web app, and the components it embeds, collect, share, retain, and protect user data. It is broader than a privacy policy because it focuses on the actual technical data flows created by the shipped product, including first-party code and third-party SDKs. In practice, the declaration is strongest when engineering, product, and security teams can validate what data is transmitted, where it is sent, and which components initiate that processing.
Definitions vary across vendors and app ecosystems, but the security value is consistent: the declaration creates a formal representation of data handling claims that can be reviewed, challenged, and updated as the app changes. The term is often discussed alongside governance obligations, yet it is not itself a control framework. For a security-led view of data handling accountability, teams often map it to NIST Cybersecurity Framework 2.0 concepts such as governance, risk management, and information protection. The most common misapplication is treating the declaration as a compliance checkbox, which occurs when teams publish a form without verifying the behaviour of embedded SDKs and network calls.
Examples and Use Cases
Implementing a data safety declaration rigorously often introduces verification overhead, requiring organisations to weigh transparency and user trust against release speed and dependency complexity.
- A consumer app declares that analytics events are collected for product improvement, then confirms that event payloads exclude account identifiers and location data.
- A health-related app states that it shares device telemetry with a crash reporting service, while engineering validates that the SDK does not capture form inputs or message content.
- A fintech app discloses that payment data is processed by a third party, but the declaration must still reflect what the app itself transmits before tokenisation.
- A product team updates the declaration after adding a new advertising SDK, because the dependency changes both data-sharing paths and user-facing claims.
- A security review uses the declaration to compare stated behaviour with observed traffic, helping identify undeclared collection or over-broad sharing.
These use cases are especially useful when product teams rely on multiple integrated components and need a shared, reviewable statement of data handling. In that sense, the declaration complements governance guidance such as the NIST Cybersecurity Framework 2.0, but it does not replace code review, dependency analysis, or privacy engineering. It is most valuable when the app evolves quickly and the data posture must remain understandable to users and auditors.
Why It Matters for Security Teams
Data safety declarations matter because they turn data handling claims into something reviewable, testable, and updateable. For security teams, the issue is not only whether an app collects data, but whether the published declaration matches what the software actually does after updates, SDK changes, or feature additions. When declarations drift from implementation, organisations can create misleading user assurances, regulatory exposure, and incident response blind spots.
Because the declaration explicitly covers third-party components, it also exposes a common weak point in modern software supply chains: teams often understand their own code better than the behaviour of embedded SDKs, agents, or analytics tools. That makes the term relevant to broader software assurance and identity-adjacent governance, especially where apps handle account data, authentication signals, or behavioural telemetry. Security teams should treat the declaration as a living artifact tied to change control, dependency review, and release governance rather than as a one-time disclosure. Organisations typically encounter the operational cost only after a product change, audit, or complaint reveals that the declaration no longer matches the app’s real data flows, at which point the term becomes operationally unavoidable to address.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
OWASP Non-Human Identity Top 10 address the attack surface, NIST CSF 2.0, NIST SP 800-53 Rev 5 and NIST AI RMF set the technical controls, and ISO/IEC 27001:2022 define the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | GV.RM-01 | Defines governance and risk management practices relevant to published data-handling claims. |
| NIST SP 800-53 Rev 5 | AU-2 | Logging and accountability controls help verify declared data flows against real system behaviour. |
| ISO/IEC 27001:2022 | A.5.31 | Information security requirements support truthful, reviewed disclosures about data handling. |
| NIST AI RMF | AI RMF informs governance where apps embed AI components that affect data collection or sharing. | |
| OWASP Non-Human Identity Top 10 | NHI guidance is relevant when apps or SDKs use tokens, service identities, or machine credentials. |
Review non-human credentials and service-to-service calls to keep declarations aligned with actual data paths.
Related resources from NHI Mgmt Group
- What breaks when organisations rely on Claude's built-in safety without external data controls?
- Why is it important to integrate identity and data governance?
- How should security teams unify identity across cloud and data center environments?
- Why is Shadow AI a governance problem as much as a data problem?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on September 1, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org