Is voluntary self-control on employee-owned iPhones considered use “in organizational settings” under the Family Controls terms?

Hello,

Apple Developer Technical Support directed me to the Developer Forums for clarification on the following Family Controls use case.

DTS reference: Case-ID 21723677

I am evaluating an iOS app called “Zone” before beginning full development. I would like to determine whether the proposed architecture is considered permitted individual device management for focus and productivity, or prohibited use “in organizational settings” under Section 3.3.3(P) of the Apple Developer Program License Agreement.

Proposed architecture:

• Zone is offered to companies as a workplace focus and productivity service.
• The app is installed on an adult employee’s personally owned iPhone.
• Participation and each Focus Session are voluntary.
• The employee independently requests Family Controls authorization using individual authorization.
• Only the employee can select the apps and websites to restrict.
• Only the employee can start or stop a Focus Session.
• During the session, Zone applies restrictions locally on that employee’s iPhone using Family Controls and Managed Settings.
• The employer cannot authorize or revoke Family Controls access.
• The employer cannot select restricted apps or websites.
• The employer cannot remotely start, stop, or schedule a Focus Session.
• The employer cannot remotely manage or control the employee’s device.

Zone would not provide the employer with:

• Screen Time or Device Activity data
• App or website tokens
• App usage history
• Website browsing history
• Information about attempts to open restricted apps
• Location, messages, photos, or other personal device information

However, Zone would include a company web dashboard. The dashboard would show only an app-generated boolean status for each participating employee:

• Zone ON: the employee has voluntarily started a Focus Session
• Zone OFF: the employee has not started a Focus Session

This status is generated by the Zone app itself. It is not derived from Screen Time usage data and does not indicate whether the employee actually attempted to use any restricted app or website.

My questions are:

1. Would this architecture be considered permitted individual device management for focus and productivity, even though the service is offered through an employer and the employer can see the Zone ON/OFF status?

2. Or would the employer relationship and company dashboard make this prohibited use of Family Controls “in organizational settings”?

3. If sharing the app-generated ON/OFF status with the employer is incompatible with the Family Controls terms, would the use be permitted if Family Controls operated entirely on-device and no Focus Session status or device information were sent to the employer?

4. Is there another Apple-supported framework or architecture recommended for this use case?

I understand that final entitlement approval and App Review decisions may depend on the submitted application. I am seeking architectural guidance before investing in implementation.

Thank you.