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Digital Advertising Alliance Will Begin Enforcing its Cross-Device Guidance February 1, 2017

The Digital Advertising Alliance (DAA), a consortium of the nation’s largest media and marketing associations that has established self-regulatory standards for online behavioral advertising, announced on October 13 that the Council of Better Business Bureaus and the Direct Marketing Association will begin enforcement of the Application of the DAA Principles of Transparency and Control to Data Used Across Devices  (DAA Cross-Device Guidance) on February 1, 2017.

The DAA Cross-Device Guidance explains how the existing Transparency and Consumer Control principles contained in the DAA’s Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data and Guidance on the Application of Self-Regulatory Principles to the Mobile Environment apply to practices that utilize data collected across devices.  Under the Guidance, a user’s choice to opt out of online behavioral advertising on a particular browser or device prevents: (1) data collected from that browser or device from being used on other linked devices for online behavioral advertising, (2) data collected from other linked devices from being used for behavioral advertising on the opted-out browser or device, and (3) the transfer of data collected from the opted-out browser or device for online behavioral advertising.

As discussed previously, the FTC held its cross-device tracking workshop in November of 2015. At the workshop, self-regulatory efforts like the DAA Principles were highlighted, as was the necessity for companies to be mindful of their representations in the context of cross-device linking.

© 2021 Covington & Burling LLPNational Law Review, Volume VI, Number 293
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About this Author

Lindsey Tonsager, Covington, regulatory and public policy lawyer
Partner

Lindsey Tonsager helps national and multinational clients in a broad range of industries anticipate and effectively evaluate legal and reputational risks under federal and state data privacy and communications laws. She co-chairs the firm’s Artificial Intelligence Initiative.

In addition to assisting clients engage strategically with the Federal Trade Commission, Federal Communications Commission, the U.S. Congress, and other federal and state regulators on a proactive basis, she has experience helping clients respond to informal investigations and enforcement...

415 591 7061
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