Updated DAA Principles – What it Means For Your Company & Clients

Nov 15, 2011 By Adam DeMartino
On November 8th, the Digital Advertising Alliance announced the first significant expansion of its self-regulatory framework beyond the initial principles that were released in July of 2009.  The 'DAA Self-Regulatory Principles for Multi-Site Data' demonstrates that the program will continue to expand to keep pace with the concerns of policy makers and regulators.  We have a living and responsive self-regulatory program. That is essential to the program’s near and long-term success. At a high level, the Multi-Site Data Principles ("MSD Principles") address three areas:  1. Expansion of Notice and Choice beyond OBA The original principles apply where data collection or use for 3rd party online behavioral advertising is taking place.  The MSD Principles supplement the original self-regulatory program and require notice and choice to  a newly defined use: 'Multi-Site Data,' which includes everything collected across websites not under common ownership.  There are important exemptions to the forms of data use that will trigger notice and choice obligations, including IP protection, security, billing, research, analytics, and product development.  But unless the business use falls under a named exemption, it will now be required to offer notice and choice.  While there are quite a few named exemptions, this new framework sets a more appropriate baseline for new business models that may emerge outside the exemptions. 2. Prohibitions of data use for adverse selection The MSD Principles specifically prohibit the use of multi-site data for a range of itemized adverse decisions, including employment eligibility, credit eligibility, health care treatment/eligibility, and insurance eligibility.  In other words, the worst targeting use cases that have been posited are now officially prohibited under the DAA Program. 3. Expanded role for Accountability Mechanisms The BBB, having recently stepped up its enforcement activity, and the DMA, now have a broader purview which includes the MSD Principles.  The new principles also outline a different type of review -- 'assurance review' -- that companies can pursue to validate non-OBA compliance.  This ‘assurance review’ would need to be conducted by an independent third-party, and, because it applies to non-OBA data collection and use, it  is not a substitute for advertisers, agencies’, networks’, DSPs’ and publishers’ obligations to deploy the Ad Choices Icon for notice and choice in ads and on websites. All of these changes are welcome and necessary, and Evidon will continue to help companies come into full compliance with their obligations under the program.  We expect that the MSD Principles will be the first in a series of updates, with international and mobile following soon.  - Colin O'Malley, CSO


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