Governance Intelligence · Framework

GDPR Mobile

Privacy by design for mobile banking apps

EU PrivacyPrivacy by DesignConsent

GDPR requirements applied to mobile banking apps — lawful basis, data minimization, consent before tracking, third-party SDK transparency, and cross-border data transfers.

Articles

GDPR full

Art. 5, 6, 7, 25, 32, 35

Mobile-relevant

Data Subject Rights

Access, Rectification, …

€20M / 4%

Penalties

Whichever is higher

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Governance Snapshot

GDPR-M • live APK index

Live

Category coverage

GDPR-LB

80%

Lawful Basis (Art. 6)

GDPR-CN

72%

Consent (Art. 7)

GDPR-DM

70%

Data Minimization (Art. 5)

GDPR-SP

82%

Security of Processing (Art. 32)

GDPR-CT

68%

Cross-border Transfers (Ch. V)

Overview

Security Goals

Why governance, AppSec and audit teams adopt this framework.

Lawful Basis

Document basis for every personal data processing.

Consent before tracking

No analytics or ads before explicit consent.

Data Minimization

Collect only what is strictly necessary.

Security of Processing

Encryption, pseudonymization, integrity.

Control Domains

Framework Control Domains

Per-domain coverage, common failures and APK evidence — expand each for detail.

5 control domains · 74% avg coverage

Lawful Basis (Art. 6)

GDPR-LB

Each processing activity must have a documented lawful basis — consent, contract, legal obligation, vital interest, public task or legitimate interest.

Coverage80%

Checks

✓Lawful basis documented per activity
✓Consent records persisted
✓Privacy notice in-app

Common Failures

✗Default opt-in analytics
✗Mixing legal bases for one activity

APK Finding Examples

Analytics SDK fires pre-consent

Recommended SDKs

OneTrustDidomiSourcepoint

View Remediation →

Consent (Art. 7)

GDPR-CN

Consent must be freely given, specific, informed and unambiguous, with easy withdrawal.

Coverage72%

Checks

✓Granular per-purpose consent
✓Withdrawal as easy as giving
✓No pre-ticked boxes

Common Failures

✗Bundled consent for analytics + ads
✗No withdrawal UI

APK Finding Examples

Single global consent toggle

Recommended SDKs

OneTrustTrustArc

View Remediation →

Data Minimization (Art. 5)

GDPR-DM

Personal data should be adequate, relevant and limited to what is necessary.

Coverage70%

Checks

✓Field-level necessity review
✓Retention schedules defined
✓Pseudonymization where possible

Common Failures

✗Collecting precise location for retail app
✗Excessive contact list scraping

APK Finding Examples

Precise location for non-essential feature

Recommended SDKs

Apple Privacy ManifestsAndroid Privacy Sandbox

View Remediation →

Security of Processing (Art. 32)

GDPR-SP

Appropriate technical and organisational measures — encryption, integrity, availability.

Coverage82%

Checks

✓Encryption in transit + at rest
✓Breach detection
✓Vulnerability management

Common Failures

✗Personal data unencrypted at rest
✗No breach response runbook

APK Finding Examples

PII in unencrypted SharedPreferences

Recommended SDKs

Android KeystoreSQLCipher

View Remediation →

Cross-border Transfers (Ch. V)

GDPR-CT

Transfers outside the EEA require adequacy decision, SCCs or equivalent safeguards.

Coverage68%

Checks

✓SCCs in place with sub-processors
✓Transfer impact assessment
✓Schrems II compliance

Common Failures

✗Analytics SDK sends data to non-adequate country
✗No SCCs signed

APK Finding Examples

Tracker endpoint in non-adequate country

Recommended SDKs

AWS / GCP EU regionsOneTrust DataGuidance

View Remediation →

Banking Implications

Why GDPR Mobile matters for Mobile Banking

Recommended posture by app type and the regulators that reference this framework.

high risk

Retail Banking

Sensitive financial data, biometrics.

Recommended

Full GDPR + DPIA

high risk

Crypto / Wallet

Frequent non-EEA processors.

Recommended

Full GDPR + cross-border SCC

high risk

Open Banking

Consent management critical.

Recommended

GDPR + PSD2

medium risk

B2B Apps

Often legitimate interest / contract.

Recommended

GDPR contract basis

Regulator Mapping

Where GDPR Mobile is referenced

RequiredRecommendedReferencedInformational

UAE CB

referenced

GCC

SAMA

referenced

GCC

MAS TRM

recommended

APAC

RBI

referenced

APAC

APRA CPS 234

referenced

APAC

FFIEC

referenced

Americas

PSD2 / EBA

recommended

DORA

recommended

Cross Mapping

Framework Coverage Matrix

How this framework maps across MASVS, OWASP Mobile, PCI DSS, PSD2, DORA and central-bank guidance.

CoveredPartialNot coveredN/A

Control	MASVS	OWASP Mobile	PCI DSS Mobile	PSD2	DORA	UAE CB
Consent & Lawful Basis	◐	○	○	◐	○	◐
Data Minimization	●	○	●	○	○	◐
Security of Processing	●	●	●	●	●	●
Cross-border SCCs	○	○	○	○	◐	○

Live APK Governance

How MobAIsec evaluates GDPR Mobile

Sample governance report from a recent assessment — coverage, gaps and top violations.

Live preview

Critical gaps1

High gaps4

Medium gaps6

Coverage heatmap

Lawful

80%

Consent

72%

Minimization

70%

Security

82%

Transfers

68%

Top Violations

Run on your APK →

Analytics fires before consent
GDPR-CN
critical
PII unencrypted at rest
GDPR-SP
high
Tracker in non-adequate country
GDPR-CT
high
Precise location for non-essential
GDPR-DM
medium

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Threat Intelligence

Threats this framework defends against

Curated mobile attack patterns aligned to the controls above.

All threat intel →

Threat

Root / Jailbreak detection

Prevent rooted-device fraud and runtime privilege abuse.

Read intel →

Threat

SSL pinning bypass

Detect and resist Frida / proxy interception of TLS.

Read intel →

Threat

Overlay attacks

Block credential and OTP theft from malicious overlays.

Read intel →

Threat

Runtime tampering

Detect APK repackaging, dynamic patching and hooking.

Read intel →

Threat

Frida detection

Prevent instrumentation-based runtime manipulation.

Read intel →

Country Mandates

Mandates using GDPR Mobile

Country regulators that reference this framework — usage confidence and mapped control count.

Browse all jurisdictions →

UAE

CBUAE

38 controls

Usage confidence92%

View country requirements →

Singapore

MAS

42 controls

Usage confidence96%

View country requirements →

India

RBI

34 controls

Usage confidence88%

View country requirements →

European Union

EBA / PSD2

46 controls

Usage confidence94%

View country requirements →

United Kingdom

FCA / PRA

36 controls

Usage confidence89%

View country requirements →

Saudi Arabia

SAMA

32 controls

Usage confidence86%

View country requirements →

Trust & Adoption

Used across banking security programs

Mobile banking security teams use this framework to establish secure release gates and runtime baselines.

EU banks

Privacy notices and consent UIs reviewed per release.

Fintechs

Use MobAIsec to surface pre-consent SDK firings before submission.

FAQ

Frequently asked questions

For BFSI CISOs, AppSec, audit and governance teams.

Is consent required before SDKs initialize?

Yes — analytics, ads and behavioural SDKs processing personal data must wait for explicit consent under GDPR Art. 6/7.

How does MobAIsec detect GDPR violations in APKs?

MobAIsec inventories SDKs, identifies pre-consent network activity, flags PII in storage and logs, and maps findings to GDPR articles.

Does Schrems II affect mobile banking apps?

Yes — transfers to non-adequate countries (e.g. US analytics) require additional safeguards. We flag any non-EEA destinations observed.

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✓Framework coverage score
✓Missing controls list
✓Fraud readiness signal
✓Executive PDF report
✓Banking mandate mapping
✓Remediation guidance

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