By Lou Mastria
ANA division reports a significant number of consumer complaints focus on digital content outside the scope of the DAA Principles, such as content, malware and ad placement.
This summer, one of our two independent Accountability Partners, the Data & Marketing Association, was acquired by another founding association of the Digital Advertising Alliance (DAA), the Association of National Advertisers (ANA). Now, DMA is known as a division of ANA, with the DMA acronym representing “Data Marketing & Analytics.” [Our other Accountability Partner is the Council of Better Business Bureau’s Advertising Self-Regulatory Council (ASRC).]
Importantly, ANA continued DMA’s accountability role of the DAA program. In fact, DMA recently released its first annual ethics report as a division of ANA. The full independently investigated and adjudicated report may be downloaded here [pdf document].
The period of the report extends back to the beginning of 2017. The report also is the sixth periodic report of DMA that includes a reference to DAA Principles enforcement as they pertain to interest-based advertising.
Consumers, business professionals, and other entities and individuals may learn about DMA’s IBA complaint mechanism here:
https://thedma.org/resources/compliance-resources/online-behavioral-advertising-compliance/
Consumers may report an IBA-related complaint using this online form:
https://thedma.org/accountability/file-a-complaint-unwanted-online-ad/
DMA recorded 665 user inquiries or complaints regarding digital advertising in the 19 months from January 1, 2017, through July 31, 2018. This compares to 491 such inquiries or complaints in 2016; 544 in 2015; and 539 in 2013-2014. In all, DMA has handled nearly 2,600 consumer inquiries.
DMA stated: “A majority of inquiries involved educating consumers on how to better manage their online ad experience” (DMA Annual Ethics Compliance Report, January, 1, 2017-July 31, 2018, p. 13). In its most recent report, five companies were referred by DMA to government agencies. Importantly, none of the five had violated the DAA Principles for Interest-Based Advertising. This high level of compliance is a testament to the advertising ecosystem continuing to value adherence to the DAA Principles.
While DMA Employs an IBA-Complaint Mechanism, It Also Reports a Variety of Content-Based Complaints beyond the Scope of the DAA Program
In our most recent Enforcement in Action 3.0 casebook, DMA reported that a variety of complaints received on the IBA-complaint mechanism do not specifically pertain to the DAA self-regulatory program. Rather, they address ad content contained in dating ads, political ads, and indecent ads — as well as complaints about ads deemed too general and not targeted enough. Also listed are numerous complaints about alleged hacking and viruses — topics not necessarily focused on advertising.
In the casebook, too, a significant number of consumer complaints focus on digital content outside the scope of the DAA Principles. These complaints relate specifically to the content or subject matter of digital display ads; the format of digital ads (pop-ups, audio, video, etc.); and perceived interference with the user’s reading of or consumption of editorial content.
A common request is for more information on how to opt out of all internet ads — whether interest-based, contextual, or generic. The DAA’s consumer-choice tools — WebChoices and AppChoices — give consumers control over data collection specifically related to IBA. They do not block content or ads.
Assistance Requested: Is a Specific Opt-Out Request Being Honored?
A minority of complaints actually involve IBA and data collection, and DMA offered assistance to these consumers regarding the opt-out process.
Some complaints are easily resolved. For example, in text that accompanies its mobile choice tools, the DAA explains that a reliable internet data connection is needed to use WebChoices and AppChoices, and that slow internet speeds can affect the download and opt-out process. DMA shares this information with each complainant when relevant.
Another common complaint is related to repetitive ads. A by-product of consumers’ clearing their cookies regularly is the removal of cookies that may be used to reduce repetitive ads (also known as “frequency capping”). While the DAA Principles call on companies to stop engaging in IBA in, for example, a particular browser following an opt-out, it permits the company in such cases to continue to use cookies for frequency-capping purposes. Consumers may also be using a different browser or device where an opt-out has not yet been applied. To help resolve these inquiries, DMA educates consumers about how to opt out, and informs them about the “Protect My Choices” plug-ins for the three most commonly used browsers in order to “harden” consumer choices. DMA aims to respond to consumer complaints to ensure fast resolution, emphasizing how the DAA choice tools work, and how individual companies’ proprietary choice tools work.
I applaud this important work – and to Xenia “Senny” Boone and her team at DMA and ANA – as we keep the DAA Accountability Principle a cornerstone and keystone of our program. By letting the consumer know that independent complaint-handling mechanisms are a click away, we help to ensure that the entirety of the IBA ecosystem stays compliant with DAA Principles.
