Snapchat settled disappearing-message claims a decade early

The design

The Federal Trade Commission announced a proposed settlement with Snapchat, Inc. on 8 May 2014, publishing its Analysis of Proposed Consent Order to Aid Public Comment in the Federal Register on 14 May 2014, under File No. 132 3078. After a public comment period, the Commission's own case record shows the final Decision and Order was entered on 31 December 2014, a distinction worth preserving since the proposed and final orders are different documents separated by seven months.

What the evidence says

The Federal Register notice sets out the FTC's complaint counts directly: Snapchat misrepresented that messages “disappear forever” after a set viewing period, when several methods existed to save them outside the app; misrepresented that senders would be notified of a screenshot, when the notification could be circumvented; misrepresented in its privacy policy that it did not access location data, when its Android app transmitted Wi-Fi and cell-based location to an analytics provider; and misrepresented the personal information its “find friends” feature collected, which included a user's entire mobile contact list. A sixth count alleged Snapchat failed to verify phone numbers, a gap the notice states let attackers compile a database of 4.6 million usernames and phone numbers in December 2013.

What it asks of people

The order does not compensate the consumers named in the complaint; it restrains Snapchat's future representations and requires structural change. It bars Snapchat from misrepresenting the extent to which its products protect message deletion, screenshot detection, data collection categories, or security measures, and requires a comprehensive privacy program with a designated accountable employee, documented risk assessments, and vetted service providers.

Privacy and safeguards

Part III of the order requires Snapchat to obtain independent, third-party privacy assessments within 180 days of the order and biennially for twenty years, a longer compliance tail than the underlying conduct. The order does not require consumer notification or compensation for the 2013 data exposure it describes; its remedies are forward-looking program requirements rather than backward-looking relief. A decade later, this order is the regulatory precedent behind the same agency's scrutiny of Snapchat's My AI companion feature, already covered on this site, since it establishes what the FTC treats as a deceptive privacy representation by this specific company.

• Which specific representations about Snapchat's My AI feature, if any, echo the categories of claim the 2014 order found deceptive?
• Has Snapchat's required third-party assessment, due to run under the order's twenty-year term, been made public in any form?
• What separates the FTC's “proposed” order in May 2014 from the “final” Decision and Order entered in December 2014?

The 2014 Snapchat matter is a decade-old precedent for the same regulator examining the same company's later AI feature, and its record shows a proposed settlement and a final order as two distinct dated documents rather than one event.