Avoiding the Enforcement Crosshairs of Cross-Device Tracking
The Digital Advertising Alliance (DAA) recently announced that enforcement of its guidance on cross-device tracking (the “Application of the DAA Principles of Transparency and Control to Data Used Across Devices”) is set to begin on February 1, 2017. Originally published in November 2015, the guidance was intended to clarify how the DAA’s Core Principles of notice and choice should be applied to cross-device tracking.
And for those of you that have not through the guidance recently…or at all… here is a quick summary:
Consumer Control: Consumers must have the ability to exercise choice (i.e., an opt-out mechanism) concerning cross-device tracking.
Although the DAA published the guidance last year, it has delayed enforcement to allow companies time to come into compliance. The guidance on cross-device tracking will be independently enforced by the Council of Better Business Bureaus (CBBB) and the DMA (formerly the Direct Marketing Association), which provide ongoing independent oversight of the DAA Principles.