BBB National Programs‘ data privacy watchdog, the Digital Advertising Accountability Program (DAAP), has issued a new compliance warning targeting “fingerprinting” of users or devices in connection with the collection or use of cross-app data.
DAAP monitors online and mobile advertising, enforcing industry self-regulation principles for data privacy and holding companies accountable to the Digital Advertising Alliance (DAA) Self-Regulatory Principles, a set of industry best practices for online and mobile interest-based advertising (IBA).
In enforcing the DAA Principles, DAAP issued this compliance warning to put companies on notice that its enforcement approach will treat any combined information used to uniquely identify a device or user for IBA as equivalent to an advertising ID in evaluating whether an entity is collecting or using cross-app data.
Under the DAA Principles, cross-app data is data collected from a particular device regarding application use over time. If a company collects this type of data and uses it for IBA, or allows another entity to do so, that company may need to provide notice, enhanced notice, or consent to the user.
Cross-app data is typically associated with a particular device by a unique advertising ID. “Fingerprinting” techniques, on the other hand, use a set of measurable characteristics – such as volume, battery level, and IP address – to identify a device. Though “fingerprinting” has been used for years, the techniques are increasingly relevant in the wake of recent platform updates that restrict or narrow an advertiser’s access to the phone’s advertising ID.
In this compliance warning, DAAP reminds companies that the DAA Principles are applicable and will continue to be enforced irrespective of the technology employed to collect and use consumer activity data to serve interest-based ads. Companies engaged in IBA must adhere to the DAA Principles, which include providing the appropriate level of transparency and choice to consumers.
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