As we enter into 2016, companies should keep in mind the Application of the Self-Regulatory Principles of Transparency and Control to Data Used Across Devices released by the Digital Advertising Alliance (DAA) toward the end of last year. This guidance builds upon the framework of the DAA’s existing principles for Online Behavioral Advertising, Multi-Site Data, and the Mobile Environment. The guidance extends the DAA’s transparency and control principles to situations where an entity collects and uses information about a user from across different browsers and devices.
Specifically, entities collecting Multi-Site Data and Cross-App Data from a particular browser or device for use on a different browser or device should disclose this in their website notice. The notice should also include a link to either a mechanism where users can exercise control over how their data is collected or to a list of all third parties engaged in these data collection practices through the entity’s website. The guidance further states that users should be able to control whether their information is collected or used across devices or transferred to a third party for that purpose.
TIP: Companies engaged in cross-device data collection and use should review their consumer notices and choice options to ensure they properly disclose their cross-device collection and usage practice and offer the user a means to opt-out.