Provision record
Apple · Apple App Store Review Guidelines · View original document ↗

Health Data Use and Sharing Restrictions

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Document Record

What it is

Generated by a model from the captured document; not read by a person

Guideline 5.1.3(i) prohibits apps from using or sharing health, fitness, and medical research data collected from specified Apple health APIs for advertising, marketing, or use-based data mining, and permits health research use only with explicit user permission. The prohibition extends to third-party disclosure for these purposes.

ⓘ

This analysis describes what Apple's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Generated by a model from the captured document; not read by a person

This provision establishes categorical restrictions on health data use that apply to all apps accessing Apple health APIs, independent of whether the app is a HIPAA-covered entity. The restriction on use-based data mining for health data is broader in its stated scope than standard commercial health data governance terms typically applied outside HIPAA-regulated contexts.

Recent Activity

This document changed recently

Medium Oct 17, 2026

The updated guidelines do not directly affect end users of apps, but they establish new requirements for developers submitting apps to the App Store. Developers must now provide regulatory documentation for apps requiring approval, implement content moderation safeguards for user-generated content and AI content creation platforms, and ensure all app information and creative assets meet specific accuracy and appropriateness standards. Developers who fail to implement safeguards or remediate violations after notice may be considered in violation of the Developer Code of Conduct, potentially resulting in app removal or account termination.

View change record →

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    To revoke an app's access to HealthKit data, navigate to iPhone Settings, select Privacy and Security, then Health, and locate the app to modify or remove its data access permissions.

If You Do Nothing

⚠ Apps that use health API data for advertising or unauthorized data mining may be removed from the App Store.

⚠ Violations of health data restrictions may trigger regulatory inquiry from the FTC or HHS OCR depending on the entity type.

Cross-platform context

See how other platforms handle Health Data Use and Sharing Restrictions and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
Apps may not use or disclose to third parties data gathered in the health, fitness, and medical research context—including from the Clinical Health Records API, HealthKit API, Motion and Fitness, MovementDisorder APIs, or health-related human subject research—for advertising, marketing, or other use-based data mining purposes other than improving health management, or for the purpose of health research, and then only with permission.

Excerpt from Apple's App Store Review Guidelines

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages HIPAA for apps operated by covered entities and business associates, FTC Act Section 5 for unfair or deceptive health data practices, and GDPR Article 9 for special category health …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has enforcement authority over deceptive or unfair health data practices for non-HIPAA-covered entities under Section 5 of the FTC Act.
    File a complaint →
  • Hhs Ocr
    HHS OCR enforces HIPAA for covered entities and business associates that access health data through App Store apps, where those entities are subject to HIPAA's requirements.
    File a complaint →

Provision details

Document information
Document
Apple App Store Review Guidelines
Entity
Apple
Date stated by the document
Oct. 16, 2026
As printed in Apple’s text (version CA-V-007653), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
March 6, 2026
Text quoted from version
CA-V-007653, captured Oct. 17, 2026
Document ID
CA-D-000025
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007653)
3f24ca77f1e96f2763031bca546e8e471c599dff98ee7a73d45dfbf3de89c260
Analysis generated
October 17, 2026 01:37 UTC
Methodology
Evidence
Excerpt not yet checked against a stored version
Citation Record
Entity: Apple
Document: Apple App Store Review Guidelines
Version: CA-V-007653
Captured: 2026-10-17 00:12:24 UTC
SHA-256: 3f24ca77f1e96f27…
URL: https://conductatlas.com/platform/apple/apple-app-store-review-guidelines/health-data-use-and-sharing-restrictions/
Accessed: Oct. 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

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Frequently Asked Questions

What does Apple's Health Data Use and Sharing Restrictions clause do?

This provision establishes categorical restrictions on health data use that apply to all apps accessing Apple health APIs, independent of whether the app is a HIPAA-covered entity. The restriction on use-based data mining for health data is broader in its stated scope than standard commercial health data governance terms typically applied outside HIPAA-regulated contexts.

Is ConductAtlas affiliated with Apple?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Apple.