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.


November Event Spotlight: IAPP Europe; The New AdTech Playbook – Accountability & the GDPR

nov 1 blog


IAPP Europe Data Protection Congress 2016

November 9 – November 10


The IAPP Data Protection Congress is where you’ll find thought leadership, a thriving professional community and unrivaled education with more than 40 sessions on the top privacy issues organisations are facing today, including the GDPR.

Visit TRUSTe in the exhibit hall at Booth #22 and hear TRUSTe’s Eleanor Treharne-Jones, CIPP/E speak alongside American Express and eBay on Nov 9th at 16:15 for “The Evolution of PIA Best Practices” and TRUSTe’s Hilary Wandall, CIPM, CIPP/E speak alongside Hunton & Williams on Nov 10th at 13:30 for “Addressing Risky Processing Under the GDPR: A Practical Approach”.

> Register here


Understanding new EU Guidance on DPIA/PIA requirements

November 10 @ 9:00 am – 10:00 am

Online Webinar

Whether you call them Data Protection Impact Assessments or just PIAs, they are an indispensable way to gauge the potential impact of projects, systems, programs, products or services on the data an organization holds. Having a good understanding of what DPIA/PIAs are, how to implement them and who needs to be involved can be the key to embedding privacy in the heart of your organization. And of course they are now a requirement for certain types of processing under the GDPR.

Make sure to save your seat for this webinar as we will:

  1. Review PIA best practices
  2. Review latest compliance guidance from the EU regulators
  3. Provide a range of tips and tools to help streamline and embed the process in your organization

Join this webinar and hear from TRUSTe’s Beth Sipula and Kellogg’s Paul Iagnocco to get the latest information, tips and tools on how to use DPIA/PIAs for new EU requirements.

> Register here


TRUSTe & DAA present: The New AdTech Playbook – Accountability & the GDPR

November 15

New York

Join the Digital Advertising Alliance & TRUSTe for an afternoon discussion to learn about the latest developments in the AdTech industry and how companies are addressing the recent self-regulation & GDPR updates. Hear from industry experts on how to mitigate risk and protect your brand surrounding these new AdTech challenges.

Panels include, “Enforced! Keeping Pace with Industry Self-Regulation Initiatives for Interest-Based Advertising Consumer” and “Is the AdTech Industry ready for the GDPR?”. Speakers include: Chris Babel, TRUSTe • Jon Brescia, Advertising Self-Regulatory Council, Council of Better Business Bureaus • Senny Boone, DMA • Jason W. Koye, Esq. CIPP US/E, Senior Counsel, Annalect, a division of Omnicom Media Group • Lou Mastria, CIPP, CISSP, Digital Advertising Alliance • Michael A. Signorelli, Venable LLP • Leigh Freund, Network Advertising Initiative.

> Request an invite here (space limited)



Awareness of DAA AdChoices Icon Rises to 42%

DAA AdChoices IconNew research findings published today, show consumer concern over online tracking for targeted ads has fallen from 65% to 61% over the last year and awareness of the DAA AdChoices icon, has risen to 42% – five points higher than last year (37%). These latest stats show the sustained growth and success of the DAA program but also what’s at stake for the digital publishing industry as 28% report they had used adblocking software in the month prior to the survey.

As consumers become more aware of how they can control the types of ads they see, they are more likely to feel positive about online behavioral advertising in general. Almost 2 in 5 (39%) said the information available through the AdChoices Icon, along with the option of opting out of OBA, would make them feel more positive about the concept of targeted ads. These findings are based on data from an online survey conducted by Ipsos, commissioned by TRUSTe, with 1,000 adults aged 18-75 in the US from December 17-22, 2015. Tracking data is available for the previous four years.

According to the survey, the business impact of consumers’ privacy concerns remains high with 89 percent avoiding doing business with companies they don’t believe protect their privacy and 74 percent of those who worry about their privacy online limiting their online activity in the last 12 months due to their concerns. Of those who worried about their privacy online, 51% did not click on an online ad in the last 12 months – the most common action taken due to privacy concerns.

The DAA program covers online, mobile and video ads and was developed in conjunction with the advertising industry to provide users with more control over their online ad experience and the option to opt-out of personal targeting without blocking ads altogether. Later this week, TRUSTe CEO Chris Babel will be speaking on a Publishers’ Roundtable titled “The Increasingly ‘Relevant’ Ad-Financed Business Model” at the Digital Advertising Alliance 2016 Summit from May 12-13.

Find out more about TRUSTe’s Ad Compliance Manager technology solution here.

May Spotlight: TRUSTe Speaking at Events in Toronto, LA and London

Screenshot 2016-04-30 09.57.18IAPP Canada Privacy Symposium 2016

May 11 – May 12


The privacy landscape is changing at breakneck speed, and your job is becoming more complex by the day. Boasting exceptional education, unmatched networking and a strong community of privacy professionals, the Symposium returns to help you step up your game.

TRUSTe’s Eleanor Treharne-Jones will be speaking on Wednesday, May 11th, 11:45am-1pm on “Are You Ready for the GDPR? Let’s Find Out.”

> Register here


Digital Advertising Alliance Summit 2016

May 12 – May 13

Los Angeles

The Digital Advertising Alliance Summit 2016 is a full-day event and provides a unique opportunity for DAA Program participants to learn about the latest developments in industry self-regulation.

TRUSTe’s Chris Babel will take part in the panel, “Publishers’ Roundtable 2016: Congratulations to the Increasingly ‘Relevant’ Ad-Financed Business Model” alongside industry experts at Viacom Media Networks, Netflix, Daily Actor, and the American Advertising Federation (AAF).

> Register here


IRMS Conference

May 15 – May 17


The Information & Records Management Society (IRMS) Conference brings together information professionals to provide an independent perspective on key challenges surrounding this years’ theme, “Information Superheroes – Enabling Business Excellence”.

TRUSTe’s Ralph O’Brien will be speaking on Tuesday, May 17th, 09.00 – 09.45 on “Hero or Villain? The Evolution of Business Information Management”.

> Register here


Global Privacy Enforcement Priorities

May 19 – 9.00am – 10.00am PT

Online Webinar

As the scope of EU law reaches around the world we are also seeing greater international regulatory co-operation. So whether it’s the FTC, the FCC or European DPAs, what are the top priorities on the agenda of global privacy regulators? How is this impacted by the rise of activism and the role of individuals like Max Schrems who have forced legal changes?

In this webinar, experts will review the latest case law and enforcement actions from the last 12 months and share their assessment on what this could mean for the future and how to keep your company out of the regulatory spotlight

> Register here




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.