Cross Border: How the DAA Program Matters to Global Advertisers

September 8, 2015

[Photo: Peter Kosmala, senior vice president of government relations at 4A's (standing) introduces the DAA Summit 2015 panel, "Cross Border: How the DAA Programs Matter to Global Advertisers." Seated left to right: Julie Ford, executive director Digital Advertising Alliance of Canada; Jeanette Fitzgerald, chief privacy officer at Epsilon; and Chris Payne, public affairs manager at the World Federation of Advertisers and board member of the European Digital Interactive Advertising Alliance.] Big Idea: Amid an ever-expanding global environment, responsible online data collection is taking hold abroad. Representatives of DAA sister programs in Europe and Canada and a global ad company discuss the approaches to self-regulation in international markets. The final panel at DAA Summit 2015, held in June in New York, featured the Digital Advertising Alliance programs in Europe and Canada, as well as the perspective of a global agency and data services provider, who discussed the importance of the DAA program and Principles, and what responsible data collection means for global stakeholders and advertisers. Peter Kosmala, senior vice president of government relations at 4A's, began the panel by discussing the well-established DAA affiliated programs in Canada and Europe and how they provide a more global perspective for responsible data collection, interest-based ads and privacy tools, as well as demonstrating the importance of transparency and control for consumers worldwide (well, 34 countries to be exact). Above the 49th Parallel: Canada... Julie Ford, executive director of the Digital Advertising Alliance of Canada (DAAC), introduced the Canadian program, and provided insight into the nation of Canada's privacy policymaking and regulatory history, beginning with PIPEDA [Personal Information Protection and Electronic Documents Act], the overarching Canadian privacy law. This law works in conjunction with data protection guidelines provided by the Office of the Privacy Commissioner (OPC), and DAAC's IBA self-regulatory Principles work within this context. Some OPC expectations for interest-based ads mirror DAA Principles: consumers being made aware of the purposes of data collection, and that organizations collecting information must do so using transparent methods such as enhanced notice. Ford also commented on the history and background of the DAAC noting: In September 2013 DAAC was launched as a nonprofit by eight leading Canadian advertising marketing associations. The DAAC works in conjunction with the U.S.-based DAA. Ghostery and TRUSTe are approved providers of DAAC in Canada, though companies may participate directly with DAAC. The program requires that companies stay away from relying on implied consent for sensitive personally identifiable information (PII). The program is consistent with Canadian privacy laws, which under PIPEDA state that sensitive PII requires opt-in consent, and that health, finance and information for children less than thirteen years of age are considered sensitive. The accountability program is administered by Advertising Standards Canada who monitors participants, accepts complaints from consumers, and investigates companies. Like the DAA in the United States, DAAC will take up Mobile Guidance of DAAC Principles next as an IBA marketplace focus. "There is [in Canada a] certain consistency with the U.S. program in terms of the organization itself as a consortium for the leading advertising and marketing groups. There is a self-regulatory code of conduct. It's similar to the U.S. but not identical. There is a user consistent experience in terms of the DAA Icon, but it’s being presented in multiple languages," 4A's Peter Kosmala said. The new Privacy Commissioner of Canada, David Therrien, was appointed on June 5, 2014. Ford notes that among the Commissioner's top five priorities, the top of the list includes, “the economics of advertising and digital advertising, specifically and not so subtly alluding to [IBA]." Ford said, "[The OPC is] open to the industry and innovation as long as we keep in mind that there are existing privacy laws in Canada, PIPEDA being one and then the [DAAC] guidelines for [IBA] being another." ...And Across the Pond: Europe "Within the commission, the program has been favorably received, interestingly I would go as far to say that it is the most robust and fully developed self-regulatory program in the digital ecosystem in Europe," said Chris Payne, public affairs manager at the WFA and board member at EDAA. "The EDAA was born through the necessity to respond to the EU Privacy Directive, which is what's known as the cookie law in Europe," said Payne noting the differences in the European digital landscape. "A lot of the time, the value of the self-regularity program is often viewed in its ability to replace legislation. In Europe we understand that self- and co-regulation, even if it does not necessarily replace legislation, can empower the industry to act responsibly and does hold value." Perspectives from a Leading Global Player "I remember back in the day when we were trying to push our clients then into just doing the DAA Principles and putting the icon on when it used to be called the forward 'i,'"; said Jeanette Fitzgerald, chief privacy officer at Epsilon. "Convincing people that this is the right thing to do because you want to show the world you're trying to do the right thing, you're being a responsible marketer and you're going to pay attention to the data you get from your consumers." "In terms of businesses there has been some great traction from U.S. companies who are doing business in Canada, coming up here with very little effort," said Julie Ford, executive director at DAAC. "I'm sure on the backend they're doing a lot, but from my perspective it seems like an easy sell for them to just expand their contract into Canada. Canadian companies it seems like takes a bit longer because we had to explain the program to them and explain that this is a global thing were trying to build here," Ford said. "To be clear when companies come online for the Canadian program there are a couple of options," said Peter Kosmala, senior vice president at 4A's. They're either existing program participants in the U.S. program and there is an agreement they can sign to extend that agreement into Canada. There is also a pure-play agreement, if you want to go just Canada. There are two different processes you can pursue but it's very straight forward," Kosmala said. European Research Shows Greater Consumer Recognition of DAA Icon "There has been some great research done by TRUSTe, in collaboration with the EDAA last year which showed that in places such as Greece, [the DAA Your Ad Choices icon has] around 40% exposure, which is quite high, and the [level of awareness] is relatively high as well," Payne said. "Some of the more interesting statistics that we’ve seen have been around the impact on consumer perception of [IBA], and the impact on consumer perception of the brands which are in the advertisements, which are serving the [Your AdChoices] icon," Payne said. "The program has to have relevance, if brands see that the impact which the icon is having from a consumer perspective is to raise the trust that the consumers have with those brands then I think that is a big win for the industry," Payne said. "In equal measure, there was a positive impact on consumer perception of [IBA] in general, that again is a big win." "A survey [internal to WFA] which was done at the end of 2014 from about 38 global brands raise a number of interesting governance challenges and I think three in particular testify to the relevance of the DAA program both in the U.S. and around the world," said Payne. "The first one is harmonization of standards: it's consistency of consumer perception of governance in the digital ecosystem and the DAA program has the ability more than any other type of legislative body to harmonize standards on a global scale, you don't see that in terms of legislation. The second element is being able to identify in a very busy ecosystem and supply chain, who the reliable parties are, who you can partner with as a responsible brand, who you are going to work with in this space and who is going to commit to your brand reputation, the way that a brand does. The [the DAA] icon, creates a sort of beacon which advertisers can identify with and partner with down the supply chain. The third priority, and this is a principal one, is how do brands stop the erosion of consumer trust online through transparency and empowerment. I think the EDAA program and the DAA program fall right into that space, making this an extremely relevant endeavor which stands to benefit both consumers and brands, and the EDAA has actually taken a number of steps to encourage the ability to communicate with consumers in a way which they understand," Payne said. Epsilon's Jeanette Fitzgerald talked about the DAA Principles serving as a global framework for jurisdictions where a DAA program still is not formally in place: "It's a way for us to explain to any of our clients, this is how we deal with data and how we recommend you deal with data, these are the issues you need to be thinking about when you're gathering your data [online], what consent you may or may not need, what your use is going to be like, why do you want that data. We look at it as a data audit... Is this something the consumer is going to expect? That varies around the world because everyone has different expectations depending on your culture. At least with the [IBA] standards with the icon, that's something you can point to as 'here is a standard that's been generally accepted, there is nothing in this other country, so let's start there and if we need to make tweaks for that country then let's do it.'" DAA thanks our global partners and participants - as brands increasingly seek borderless conversations with their stakeholders, and DAA Principles help make that happen in a responsible manner.

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