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 on InsidePrivacy, 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.

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Photo of Lindsey Tonsager Lindsey Tonsager

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.

In addition to assisting clients engage strategically with the Federal Trade Commission, the…

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.

In addition to assisting clients engage strategically with the Federal Trade 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 actions, including by self-regulatory bodies such as the Digital Advertising Alliance and Children’s Advertising Review Unit.

Ms. Tonsager’s practice focuses on helping clients launch new products and services that implicate the laws governing the use of endorsements and testimonials in advertising and social media, the collection of personal information from children and students online, behavioral advertising, e-mail marketing, artificial intelligence the processing of “big data” in the Internet of Things, spectrum policy, online accessibility, compulsory copyright licensing, telecommunications and new technologies.

Ms. Tonsager also conducts privacy and data security diligence in complex corporate transactions and negotiates agreements with third-party service providers to ensure that robust protections are in place to avoid unauthorized access, use, or disclosure of customer data and other types of confidential information. She regularly assists clients in developing clear privacy disclosures and policies―including website and mobile app disclosures, terms of use, and internal social media and privacy-by-design programs.