DAA Issues New Guidelines for Online Collection and Use of “Multi-Site Data”

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The Digital Advertising Alliance (DAA) has announced a new set of guidelines that significantly expands the requirements for member companies that collect data online. The Self-Regulatory Principles for Multi-Site Data establish broad and comprehensive standards governing the collection and use of data from an individual’s device, regarding internet viewing over time and across non-affiliated web sites – what DAA is calling “Multi-Site Data.” These guidelines go well beyond DAA’s existing guidelines governing the collection and use of data for online behavioral advertising (OBA). They apply to data that is collected for any and all purposes (not just OBA), with limited exceptions, and explicitly prohibit the collection of data for specific purposes related to employment, health care, credit and insurance.

The guidelines apply to “any entity” that collects Multi-Site Data, including “First Parties” (defined as “the entity that is the owner of the Web site or has Control over the Web site with which the consumer interacts and its Affiliates”) and their affiliates, “Third-Parties” (defined as an entity that “collects Multi-Site Data on a non-Affiliate’s Web site”) and Service Providers (including, for example, an internet service provider or provider of a toolbar or internet browser).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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