The Online Interest-Based Advertising Accountability Program is serious about compliance with the transparency and consumer control provisions of the Digital Advertising Association's Self-Regulatory Principles for Online Behavioral Advertising. This week, the Program issued a new compliance warning clarifying that websites will be held to those "enhanced notice" requirements for "native" advertising that is created or targeted through the use of online behavioral advertising. The announcement warned that enforcement will begin January 1, 2015, and all companies that incorporate interest-based native ads into their sites should ensure that they satisfy the enhanced notice requirements before that date. High-traffic sites in particular should expect compliance reviews beginning in the new year. This compliance warning follows the Program's release of several decisions in late October 2014 (see press release here) against prominent companies whose websites were found to have fallen short of full compliance with the self-regulatory program's enhanced notice requirements.
Whether a company's site is established, revamped or new, the recent decisions serve as a reminder to check the website in its entirety to ensure that privacy features, and specifically the enhanced notice requirements, are compliant.