The Data safety form is a declaration in Play Console, under App content, where you describe what user data your app collects and shares and how you handle it. You need it before your app can be on a closed, open or production track, even if your app collects no data at all, and you need a privacy policy link to complete it. The most common mistakes are forgetting data that your SDKs send and misreading what "collection" and "sharing" mean.
Who needs to fill it in
Google's Data safety help page is clear on two points:
- "Even developers with apps that do not collect any user data must complete this form and provide a link to their privacy policy."
- "Apps that are active on internal testing tracks are exempt from inclusion in the data safety section."
So an app that only lives on internal testing can skip it for now. The moment you set up a closed test, which you must do to meet the 12-tester requirement, the form becomes part of your app setup. It's one of the items in our checklist before day 1, and it's worth finishing before you build your closed testing track.
Before you open the form
Gather three things first. It saves a lot of back-and-forth.
- A list of every SDK and library in your app that touches the network: analytics, crash reporting, ads, sign-in, payments, push notifications, maps, backend services.
- What each one sends off the device. Check each provider's documentation. Google points developers to the Google Play SDK Index, where many SDK providers publish data safety information.
- Your privacy policy URL. The form can't be completed without it, and the policy should describe the same data you declare.
What "collection" and "sharing" mean
Most wrong answers come from everyday definitions. Google uses specific ones.
Collection
Collection means "transmitting data from your app off a user's device." That includes data sent by third-party libraries and SDKs, wherever it goes, and data from webviews your app controls.
Some data doesn't need to be declared as collected:
- data processed only on the device and never sent off it
- data sent with end-to-end encryption, unreadable by you or intermediaries
- data processed ephemerally: accessed in memory only and "retained for no longer than necessary to service the specific request in real-time"
Sharing
Sharing means transferring user data to a third party, for example server-to-server, on the device, or through an SDK or webview you control.
Some transfers don't count as sharing:
- to a service provider that processes data "on behalf of the developer and based on the developer's instructions"
- for legal reasons
- initiated by the user, where they'd reasonably expect it to be shared
- fully anonymized data
A crash reporting SDK that sends device details to its own servers is collection. Whether it's also sharing depends on whether the provider acts as your service provider. Read the provider's documentation rather than guessing.
Step by step
- In Play Console, go to Policy and programs > App content.
- Find Data safety and select Start (or Manage if you've begun).
- Read the overview.
- Answer whether your app collects or shares any of the required user data types.
- Answer the questions about encryption in transit and data deletion.
- Select every data type your app collects or shares, for example location, personal info, app activity, or device or other IDs.
- For each data type, answer how it's used and handled: collected, shared, or both; required or optional; and for which purposes.
- Review the preview of how the section will appear on your store listing.
- Save as a draft, or submit.
Two badges to declare carefully
Encryption in transit
Only declare this if it applies to "all user data that their app (including all its SDKs and libraries) collects and transmits off the user's device." One plain-HTTP call in an old library makes this answer wrong.
Data deletion
You can declare this if you "provide users with a mechanism to request data deletion", or if you "automatically initiate deletion or anonymization of collected data within 90 days of collection." If your app has accounts, check what Google currently expects for account deletion in the App content section, because those requirements sit next to this form.
Mistakes that cause problems
- Answering "no data collected" while using analytics, ads or crash reporting. These SDKs almost always send something off the device.
- Copying another app's form. Your SDK list, backend and purposes are different.
- A privacy policy that contradicts the form. If the policy mentions location and the form doesn't, one of them is wrong.
- Forgetting to update after a release. Adding a new SDK in version 1.3 can change your answers. Review the form whenever your dependencies change.
- Assuming Google checks it for you. Google says it "cannot make determinations on behalf of the developers of how they handle user data." You are responsible for accuracy.
Inaccurate declarations matter. If Google finds a discrepancy between what the app does and what you declared, "we may take appropriate action, including enforcement action." During closed testing, a problem with your declarations can also hold up the review of your release, which delays the start of your 14 days.
A short checklist
- Every network-using SDK listed, with what it sends
- Collection vs sharing decided using Google's definitions
- Encryption in transit only if it's true for all data
- Deletion answer matches what your app really offers
- Privacy policy URL live and consistent with the form
- Form reviewed again before each release that changes dependencies
Where this fits
The Data safety form is one of several App content declarations, along with the privacy policy, ads, app access, target audience and content rating. They all need to be in place before your closed testing release goes to review, and Google asks you to check content and store listing accuracy again before you apply for production. Our production access guide covers that last step.
If your declarations are done and you need testers for the 14-day closed test, GoPlayTester provides 12+ real testers on real devices; Google makes the final decision on access. See the setup guide for how it works.
