The Online Interest-Based Advertising Accountability Program, is one of two entities charged with enforcing compliance with Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. It recently issued a COMPLIANCE WARNING to its members setting out some pretty strict guidelines for “enhanced notice” to alert consumers that a Web site advertiser is gathering data for purposes of online behavioral advertising. Interestingly, though, the compliance burden seems to fall more on the Web site operator than it does on the advertiser.
It’s not clear how the industry will react to this mandate. In my view, convenience rules the day. If I’m in a hurry, and anxious to complete a purchase, I’m not going to get too worked up about how the Web site uses my information. I suspect I’m not unusual in that respect. Which means that disclosing the OBA information probably won’t disrupt sales. And in the privacy/data collection arena, it’s hard to be too transparent.