5.1.1 account deletion issue: what is a highly regulated industry?

Hello,

I'm posting about a 5.1.1 compliance issue with account deletion.

The issue I am running into is that we use a customer service flow (email) to initiate account deletion. Now, it is not explicitly stated that email cannot be used in the 5.1.1 Guideline, but in a linked FAQ which states that only "Apps in highly regulated industries, as described in App Store Review Guideline 5.1.1(ix), may use additional customer service flows to confirm and facilitate the account deletion process."

However, 5.1.1(ix) does not list what a highly regulated industry is, or how it can be determined. It just lists some examples: "Apps that provide services in highly regulated fields (such as banking and financial services, healthcare, gambling, legal cannabis use, and air travel)".

If the industry your app is used in, is not one listed in these examples, but is still considered to be highly regulated, what do you need to provide to show it is a highly regulated industry?

What qualifies an industry to be highly regulated?

In my case, we have provided additional information and documentation citing various regulatory acts that govern the industry. We were told we cannot use email, but Apple documentation states that we can if we are a highly regulated industry. I keep asking if Apple considers the industry to be highly regulated or not, but so far no answers.

Any insight on how Apple defines a "highly regulated industry", or how you've resolved a similar issue with Apple would be appreciated.

Thank you!

If anyone has any insight, please reply! Thanks for reading my post

Still an ongoing issue as of October 11, 2022

Accepted Answer

After 2 months, I was able to get an answer on what Apple considers to be a highly regulated industry.

It turns out the examples listed in 5.1.1(ix) - "highly regulated fields (such as banking and financial services, healthcare, gambling, legal cannabis use, and air travel)" - are the ONLY industries that Apple considers to be highly regulated. Apple does not consider commercial fishing to be a highly regulated industry.

This is extremely misleading. I submitted feedback requesting this be clarified in 5.1.1(ix) of the App Store Review Guidelines. If you experienced a similar issue, I suggest you do the same here: https://developer.apple.com/contact/app-store/ and select 'suggest a guideline change'.

5.1.1 account deletion issue: what is a highly regulated industry?
 
 
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