Reminder: Enhanced Notice & Choice to Consumers is a ‘Shared Responsibility’

November 17, 2014

Recently, our accountability partners at the Council of Better Business Bureau’s (CBBB) Advertising Self-Regulatory Council (ASRC), made public its compliance work with five Web sites to ensure enhanced “real-time” notice is given to consumers when data on their sites, within the scope of Digital Advertising Alliance Principles, is being collected and used by Web sites’ third-party partners.

According to ASRC,

“Notice and choice on interest-based ads are delivered through the familiar Advertising Option Icon (AdChoices Icon). Over a trillion impressions of the AdChoices Icon are served each month, according to DAA statistics, evidence of the depth of compliance among advertisers and third parties responsible for delivery of in-ad enhanced notice. Today’s decisions remind website publishers that they must shoulder their responsibility to ensure that the delivery of enhanced notice is just as ubiquitous when third-parties are collecting data for OBA [interest-based ads] on their websites. In either situation, a consumer should be able to click on the enhanced notice link and go directly to a place where they can learn more about interest-based advertising and find an opt-out tool.”

There needs to be live links to explanations of the data collection, and how the data is used to serve interest-based ads, and to enable an opt-out choice.  (Note:  A mobile-responsive version of the DAA industry-wide Consumer Choice Page is now in development, as is AppChoices, a mobile app providing choice functionality regarding data collection in the in-app environment.)

Another question that’s often asked is who in the advertising supply chain takes “ownership” of DAA compliance.  Simply said, according to CBBB, it's a shared responsibility. The advertiser, the media buyer, the ad agency, the ad networks and the publishers all need to understand the growing interest-based ad ecosystem and not assume someone else has covered the industry self-regulation base.  Due diligence must incorporate documentation of DAA Principles’ adherence. 

We thank our two accountability partners for their continued hard work of fostering an ecosystem of compliance with the DAA Principles. It is this code of conduct that empowers the ability of consumers to access the ad-funded content and services that they enjoy while meaningfully implementing enforceable privacy controls

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