On November 16, 2015, the Digital Advertising Alliance (DAA) released guidance, titled the Application of the DAA Principles of Transparency and Control to Data Used Across Devices (Guidance), to help companies apply the DAA Self-Regulatory Principles to the quickly expanding cross-device environment.9 The Guidance makes clear that the transparency and control obligations of the current DAA Principles apply with respect to cross-device data practices, and are subject to the DAA’s independent enforcement.
The cross-device guidance clarifies how the transparency and consumer control principles apply to browser and app-based opt-out choices made by consumers regarding how data collected on that browser or device may be used elsewhere, and how data collected on other browsers or devices may be used on the device where a choice was made. Like the DAA’s Application of Self-Regulatory Principles to the Mobile Environment (Principles) – which went into effect in September 2015 – the cross-device Guidance when effective will be enforced by the DAA accountability programs.
A recent survey found that 79% of consumers aged 18-64 use at least three devices a day, representing a shift from a single screen to a multi-screen norm.10 Keeping pace with innovation and changing consumer preference, the DAA convened an inclusive group of leading companies and associations in the digital advertising ecosystem to develop the Guidance as an initial step in applying the DAA Principles in the cross-device space. The Guidance represents another example of the DAA’s adaptation to the ever-changing digital advertising space, as well as the flexibility of self-regulation to keep pace with the marketplace.