Mobile app GDPR audit: what to check, and how to prove it

An app declares itself in a privacy policy, but it acts in the traffic it emits. An audit confronts the two: which third parties fire, what data leaves, when relative to consent. Here is the full method, the deliverable, and what it costs.

Why audit a mobile app, and why now

In 2025, the CNIL made mobile apps one of its priority inspection themes. In France, Article 82 of the Data Protection Act governs any reading or writing of information on a phone, and the GDPR requires you to demonstrate compliance.

95

third parties fired despite the tracking refusal, across 20 news apps.

Read the full study

2025

Mobile apps, one of the CNIL’s priority inspection themes.

What a CNIL inspection checks

What a mobile app audit must verify

  • The third parties actually active

    Every SDK and third party that fires during use, with the domain contacted and its category: advertising, audience measurement, attribution, social networks. Including the ones firing in the background.

  • The personal data that leaves

    The identifiers and data transmitted off the device, who they go to, and whether they circulate across several third parties at once.

  • The timing, against consent

    What fires before the banner, while it waits for an answer, and after a refusal. The timing is often the real issue.

  • The banner against the active parties

    The parties the consent screen declares, compared with the ones actually firing, from the IAB list or added outside it.

  • Permissions requested and used

    The ones the app asks for, when it asks, and the ones it actually uses during the journey. Proportionality is judged on use.

  • Where the data goes

    The country of each contacted server, the host sitting behind it, and that country’s data-protection level per the CNIL referential.

The method: observe the app as it runs

  • Read the declarations

    The store listing, the privacy policy, the list of announced partners. Necessary, but declarative: nothing there proves what the app does once installed.

  • Inspect the package

    Static analysis lists the libraries embedded in the installer file. Useful as an inventory, silent on behavior: a kit can sit there and never fire, and what leaves cannot be read from it.

  • Observe the execution

    The app runs on a real phone, a real journey is followed, consent banner included, and every outgoing exchange is recorded, decrypted and dated. This is Skanopy’s method, fully automated.

  • Replay on every version

    An update can add an SDK or switch a partner with nothing moving on screen. The same journey replays on each version, and the reports compare from one release to the next.

Read, inspect, observe: only observation shows what actually leaves. And a finding only holds for the version observed.

What the CNIL expects, proven on your apps.

Consent first

Every exchange, timed against the choice made in the banner.

Third-party SDKs under control

The active actors and the company behind each domain.

Permissions kept to a minimum

The permissions requested, when, and the ones used.

Accurate information

The declaration, against what leaves the device.

A refusal just as easy

What still transmits after a refusal, actor by actor.

No technical skills required.

  • A Google Play Store link
  • Or the .apk of an unreleased version
  • No integration in the app
  • On real phones
  • A real user journey replayed
  • Every exchange logged
  • A recommended action per finding
  • A priority and dated evidence
  • The fix verified on the next version

How much does a mobile app audit cost?

Flash audit

Free

See which third parties your app contacts, with nothing to commit to.

  • Mapping of active third parties and SDKs (software components built into the app)
  • First screens of the app
  • PDF summary sent by email
  • Results within 48 hours

One app per request.

Custom

On quote

Your most complex journeys, tailored to your app.

  • Everything in the full audit, plus:
  • Strategic journeys: checkout, subscription, video playback…
  • Granular consent settings
  • Priority analyses of your apps
Compare the plans

Frequently asked questions

The audit

  • It is the comparison between what an app declares and what it actually does once it runs. A mobile app compliance audit records, on a device, the third parties contacted, the identifiers and data sent, the permissions used and the timing of each transmission relative to consent, then sets those findings against the privacy policy, the store listing and the record of processing activities. It produces dated, repeatable facts rather than an opinion: the legal qualification stays with the data protection officer.

  • In three steps: install the app on a real phone, follow a real usage journey, consent banner included, then record every outgoing exchange, decrypted and dated. The findings are then set against what the app declares. This is what Skanopy automates end to end, with no access to the source code.

  • A website can be observed from the browser’s own tools. An app is a compiled binary with encrypted traffic, often hardened against analysis: its exchanges can only be read by running it on a controlled device. That is what makes its audit more demanding, and rarer.

  • A Google Play link, or the installer file if the app is not published yet. No access to the source code, no kit to integrate, nothing to install in your infrastructure.

  • On every release that changes an SDK or a partner, and at a regular cadence at minimum: an update can change behavior without the banner moving. The reports of two versions read side by side.

  • No. The analysis currently covers Android apps, from a Google Play link or an .apk file; iOS is on our roadmap. Analyses are processed in the European Union.

See what your app really transmits.