Case Resolution Types

 

DAAP, through its technology platform and staff research and monitoring, reviews the practices of companies collecting and using information across websites and over time to tailor ads to consumers’ interests and for other purposes covered by the Self-Regulatory Principles for Online Behavioral Advertising, the Self-Regulatory Principles for Multi-Site Data, and the Application of Self-Regulatory Principles to the Mobile Environment (collectively the Principles). 

 

When DAAP determines that there may be a compliance issue regarding a company’s adherence to one or more of the Principles, DAAP may, in its discretion, send the company a letter of inquiry asking the company to demonstrate its compliance with the Principle or Principles at issue. 


If DAAP, after receiving the company’s answer, determines that further review is warranted, it will begin a formal review process in which it provides the company with guidance and recommendations. At the end of the formal review, DAAP will publicly release a decision detailing the nature of the review and its outcome, along with a press release summarizing the decision. Decisions will provide guidance on the requirements of the Principles at issue for all companies in the advertising ecosystem subject to these requirements. Decisions will also discuss a company’s efforts to implement DAAP’s recommendations to come into compliance with the Principles, as appropriate. 


In instances where a company fails to participate in the review process or to implement the recommendations, DAAP will issue a press release detailing the facts and the company’s response to the inquiry. In addition, DAAP may, in its discretion, refer the matter to the appropriate government agency for further action. 


In special circumstances, DAAP may, as provided under its Procedures, choose to administratively dispose of the inquiry or, rarely, to administratively close the case. 


Copies of all final decisions, administrative dispositions, and administrative closures are available below. 

 

Decisions

 

Administrative Closures

 

Administrative closures are numbered for the record and generally provide insight into the nature of the inquiry and why it was closed, but the names of the companies involved are not publicly available. 

 

Administrative Dispositions

 

Administrative dispositions are issued when an inquiry determines a company was already engaged in efforts to bring its practices into compliance with the Principles at the time the formal review was initiated. An administrative disposition is a short document that states the nature of the inquiry and the reasons for its disposition. Administrative dispositions are made public. 

 

Program Guidance

 

In keeping the mission of the program to promote compliance with the Principles, DAAP may, in its discretion, supplement the industry guidance it provides through the issuance of public decisions, press releases, and other adjudicatory documents, by issuing a Compliance Warning or general Compliance Guidance, prior to formal enforcement. Compliance Warnings and Guidance documents will be posted here. 

 

We note that DAAP also conducts educational outreach to companies and consumers to help them understand the Principles. Such educational outreach includes participating in webinars, conferences, and other public events, as well as working with other organizations that share its goals. 

Referrals

Formal Review

Formal Review 102.2019 - PlantSnap, Inc.

The BBB National Programs’ Digital Advertising Accountability Program referred the mobile app developer PlantSnap, Inc. to the Federal Trade Commission today. The referral was initiated after PlantSnap failed to participate in a self-regulatory review process looking into data privacy practices related to geolocation data and advertising.
Read more
Formal Review

Formal Review 93.2019 - HyperBeard, Inc.

Two industry self-regulatory units of the Council of Better Business Bureaus today referred the mobile app developer HyperBeard to the Federal Trade Commission (FTC) for failure to participate in a self-regulatory review process looking into data privacy practices related to children and advertising.
Read more
Formal Review

Formal Review 33.2014 - SunTrust Bank, Inc.

The Online Interest-Based Advertising Accountability Program (Accountability Program) today referred SunTrust Bank, Inc. (SunTrust) to the Consumer Financial Protection Bureau after SunTrust refused to participate in the advertising industry’s self-regulatory process. The Accountability Program uses this cooperative inquiry process to help companies understand and comply with the cross-industry...
Read more