DAA Cross Device Guidance Enforcement Starting Today

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.


Implementing the new DAA Video OBA Guidelines

Helen Huang, Senior Product Manager, TRUSTe


The DAA released Video OBA guidelines in November 2015, which apply to in-stream video ads (pre-roll, mid-roll, post-roll), in-page and in-banner ads. Unlike desktop, the video ad serving industry standards are fragmented leading to more business and technical considerations for companies.

In light of the new video guidelines, although there are significant overlaps with previous desktop and mobile guidelines, here are some key highlights below:

  • Implement the icon where it would least conflict with the video experience, taking into consideration: corner of icon, video coloring, and other embedded calls of action.
  • The icon should not “float” within a video ad.
  • The icon should persist throughout the video ad; But if the user suspends the video ad to engage with an interactive element, the icon doesn’t need to be in the element. However, the icon should remain or re-appear when the user returns to engage with the video ad.
  • If clicking on the icon opens an interstitial, the interstitial should cover less than 50% of the video.
  • While the (optional) interstitial is expanded, the company has the option to continue to play or pause the video ad.
  • Finally, companies may work with publishers to place the icon adjacent to the video and if there are technical implementations with an icon overlay.

Depending on where the company is in the chain of video ad serving and the creative format it has to work with, the company has a range of implementation options including a raw impressions/click pixels, flash component, js component, swf files in AS2 or AS3, or VAST 3.0.

Since many companies are still on VAST 2.0, it’s important to note that the DAA guidelines also recognize this as a difficulty for the industry.

“Given the diversity of video players and formats across the desktop and mobile environments, the DAA recognizes that in some cases serving a clickable Ad Marker is not possible in connection with video ads. However, when serving the Ad Marker is not possible for participating companies, the examples presented in these Guidelines are intended to help such companies deliver a consistent consumer experience.”

1 For example, video ads in VAST 2.0 format do not natively support the inclusion of a clickable Ad Marker.

TRUSTe has seen many businesses approach the implementation differently. Buy-side companies tend to require the icon within their contracts with the video partners they work with. This is aligned with companies pushing others to include the notice where it makes most technical sense while the industry evolves to a standard where the implementation is scalable. Networks that have native ad servers tend to pick one of the technical implementations above and apply them across all their inventory and campaigns.

Even though the industry is working through these technical challenges, video advertising is increasing in popularity within the ecosystem across desktop, mobile and smart tv. The video DAA guidelines remind us that consumer choice needs to be offered in video because notice and choice is important to protecting a user’s privacy regardless of format and platform.

TRUSTe has supported a video OBA solution since 2012 and is able to support all technically possible ways of integrating the icon into a video ad. If you are serving behaviorally targeted video advertising and need assistance in implementing the OBA icon in your video ads, please talk to a TRUSTe representative or contact me for any questions on hhuang@truste.com

To find out more about the new video guidelines and the latest DAA developments register for our webinar “2016 DAA U.S. Update: What Recent Innovations Mean” on Thursday January 21 from 10-11am PT. You can register here.