The Digital Advertising Alliance (“DAA”) released initial guidance to assist companies apply the current DAA's Self-Regulatory Principles (in particular, Online Behavioral Advertising Principles, Multi-Site Data Principles, and Mobile Principles ) in the rapidly growing cross-device environment. The guidance, titled "Application of the DAA Principles of Transparency and Control to Data Used across Devices", aims to help participants in the digital advertising ecosystem better understand their obligations regarding cross-device data.
The guidance makes clear that the transparency and choice obligations in the existing Self- Regulatory Principles apply to cross-device data practices, which are also subject to the DAA's independent enforcement.
The DAA recommends that entities should include notifications on their websites or apps which describe their data collection and use practices, as well as the fact that data collected from a particular browser or device may be used with another computer or device. This notification should also include the fact that exercising choice through user choice mechanisms, may limit such collection and use. In addition, when data is collected or used on a website or through an application, the website or the application should provide a clear, meaningful, and prominent link to a disclosure that either links to a choice based mechanism, that provides control consistent with the Self-Regulatory Principles, or lists third-party entities which are engaged in the collection of multi-site or cross-app data through its website or application.