TrustArc Blog

DAA Cross Device Guidance Enforcement Starting Today

February 01, 2017

Digital Advertising Alliance (DAA). (PRNewsFoto/Digital Advertising Alliance)

In a typical day the average person will use several devices to make calls, check emails, or watch videos. Over half of people (57%) who use a device such as a smart phone or tablet use more than one.[1] It is easier than ever to seamlessly move between devices and continue an activity on one device where you left off on another. Users get the advantage of a seamless experience across devices, and publishers and ad tech companies can get information about user behavior across those devices, which is known as cross-device tracking.

Starting today, February 1, 2017, the Digital Advertising Alliance (DAA) Guidance on how the DAA Principles of transparency and choice apply to cross-device tracking will be enforced. 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 take complaints and monitor the marketplace to ensure that transparency and choice are provided to consumers when there is cross-device data collection.

DAA Executive Director Lou Mastria commented that

the DAA Cross-Device Guidance provides clarity for both first and third parties on how to extend notice and choice in accordance with DAA Principles. It also helps keep the cross-device interest-based advertising environment in step with consumer expectations. Over and over again, in our surveying, consumers say they value the transparency and control made possible in our program, so to extend notice and choice certainly serves to build brand engagement, no matter what the device she uses. With DMA and the Council of Better Business Bureaus Advertising Self-Regulatory Council all set to begin enforcement on February 1, every marketing organization relying on interest-based ads in cross-device environments should be ready to meet these ethics — and user — expectations.

The overall benefits and challenges that come with cross-device tracking are explained in this recently released report: Cross-Device Tracking: An FTC Staff Report. The report makes recommendations about how transparency, choice, and security can be applied to this practice. It also encourages organizations that have direct consumer-facing relationships and those working in cross-device tracking behind the scenes to (1) truthfully disclose tracking to consumers and business partners; (2) offer consumers choices about how their cross-device activity is tracked; (3) obtain consumers’ affirmative express consent before engaging in cross-device tracking on sensitive topics and before collecting and sharing precise geolocation information; and (4) maintain reasonable security to avoid future unexpected and unauthorized uses of data.

The report states that “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.”

Enforcement of the Guidance will help maintain consumers’ data privacy across devices.

Learn more about mobile principles and how they help consumers, or find out more about how TRUSTe can help you comply with the DAA Cross Device Guidance here.

[1] Google Data, “How People Use Their Devices,” based on convenience sample of opt-in U.S. cross-device users, ages 18–49 who signed into Google and turned on Location History (mobile Android-only and IE/Chrome/Firefox desktop browser); calibrated to population studied, Jan. 2016–Mar. 2016; location analysis excludes locations that are not identifiable; apps include browser apps; search includes Google Search only; a store refers to a commercial entity that offers services or goods (examples: department store, big box retailer, clothing store); entertainment venues include movie theaters, stadiums, and other public entertainment spaces.