By Lou Mastria
Our Accountability Partners are ready to begin the enforcement phase of DAA’s Cross-Device Guidance -- the next step in a process that we, as the responsible digital ad industry, started almost 2 years ago with initial development of the guidance itself.
This coming week, our latest interpretation of these Principles – our Cross-Device Guidance – takes enforcement effect, on February 1. This process began nearly two years ago, leading up to the release of the Guidance at the FTC’s Cross-Device Workshop in November 2015 and alerts about forthcoming accountability that began October 2016. Only this week, the Federal Trade Commission, in its latest staff report on cross-device data collection in the marketplace, included this statement of support:
"FTC staff commends these self-regulatory efforts to improve transparency and choice in the cross-device tracking space. Both the NAI and DAA have taken steps to keep up with evolving technologies and provide important guidance to their members and the public. Their work has improved the level of consumer protection in the marketplace.” (Page 11, “Cross-Device Tracking: An FTC Staff Report,” January 23, 2017).
The collective work on the DAA Cross Device Guidance and forthcoming accountability work is just one more way in which we are using self-regulation to ward off more onerous regulatory initiatives as well as preserving responsible brand engagement of cross-device data collection for interest-based advertising purposes, to make sure notice and choice are being afforded to the consumer.
What does the enforcement phase mean?
On February 1, our two U.S. Accountability Partners – the Advertising Self-Regulatory Council (ASRC) of the Council of Better Business Bureaus (CBBB)and the corporate responsibility team at the Data & Marketing Association (DMA) – will begin taking complaints and monitoring the marketplace for first-party and third-party transparency and choice to consumers as they pertain to cross-device data collection for interest-based advertising (IBA).
DAA itself is updating its own disclosures – effective February 1. There will be updates to both our WebChoices tools for desktop and mobile Web and inside our AppChoices and AppChoices en Español (for cross-app) mobile application. This new language will explain the scope of a consumer choice expression via these industry choice tools. For example, and in summary, the new language in AppChoices will provide notice that consumers can make choices about the:
“…collection and use of cross-app data on this device for Interest-based Advertising and other applicable uses by some or all of the companies participating in AppChoices.” The language will also point out that, “…choices will also apply to the collection and use of data from apps on this device to customize ads on other browsers or devices… [a]dditionally, these choices will apply to data collected…from other browsers or devices for use in apps on this device for Interest-based Advertising and other applicable uses.”
Our goal is to make it clear to the consumer, who uses DAA choice tools, that her expression of choice pertains only to the device and browser on which she exercises that choice. No browsing and usage data may flow into or out of that device/browser for the purposes of IBA, if the consumer has expressed a choice on that device/browser.
So as we move to create more relevant advertising using cross-device data – let’s be sure we keep true to our principles of enhanced transparency and consumer control. The reward is better consumer engagement and confidence through a responsible IBA ecosystem with meaningful accountability, which we all helped to create and foster through the DAA.
Note: A recent DAA webinar with the Data & Marketing Association offers a helpful resource for interest-based advertisers, and their partners, as they implement the Cross-Device Guidance.