Today, the Digital Advertising Accountability Program released new actions detailing its efforts to provide consumers with marketplace choice about their digital privacy. As a result of consumer complaints, the privacy watchdog brought the companies Johnson & Johnson Consumer Inc. and PVH Corp. into compliance with the Digital Advertising Alliance’s Self-Regulatory Principles, best practices for digital ad privacy.
As a result of a consumer complaint filed with the Accountability Program, the privacy watchdog initiated a review of the website for the Johnson & Johnson Consumer Inc. skin care brand Neutrogena. After being contacted, Johnson & Johnson Consumer Inc. committed to implement the requirements of the DAA Principles and pledged to add a real time, “enhanced” notice of its data collection practices to the Neutrogena website.
Furthermore, Johnson & Johnson Consumer Inc. took the additional steps of:
- updating its privacy disclosures to meet the requirements of the Mobile Guidance, the set of the DAA Principles that covers IBA on mobile apps, and
- committing to the addition of an enhanced notice link for its mobile app offerings, accessible through the Google Play and Apple App stores, which takes users directly to information about IBA occurring through these mobile apps.
After taking these actions, Johnson & Johnson Consumer Inc. conducted an audit of its entire suite of websites and mobile apps and updated over 70 of its digital products to meet its obligations under the DAA Principles.
PVH Corp., the subject of today’s second case, is a company that owns popular clothing lines such as Tommy Hilfiger and Calvin Klein. The Accountability Program identified the company after a consumer complained about ad targeting following a visit to the True&Co website, a women’s intimates brand owned by PVH. After seeing evidence of data collection for interest-based advertising on this site—but no enhanced notice—the Accountability Program sent an inquiry letter to the company about its privacy practices.
Once contacted, PVH committed to full compliance with the DAA Principles for all of its digital properties. Working with the Accountability Program, the company added an “Interest Based Ads” link to its eCommerce clothing websites. The new link takes website visitors to a disclosure informing them that data collection for targeted advertising occurs on PVH websites and pointing them to a consumer choice tool.
“The DAA Principles apply to companies large and small,” said Jon Brescia, Accountability Program VP. “We appreciate the work that Johnson & Johnson Consumer Inc. and PVH did to overhaul so many properties to come into compliance with best practices for IBA. The eagerness and thoroughness demonstrated by both companies in reaching compliance highlight once again the effectiveness of self-regulation.”