On November 25, 2019, the Digital Advertising Alliance announced it is developing cross-industry tools for publishers, brands, agencies and adtech to provide a mechanism to opt out under the California Consumer Privacy Act, which takes effect on January 1, 2020. These tools align with the DAA’s self-regulatory guidelines and are intended to provide consumers with a simple mechanism to opt out of the sale of data under CCPA not only for the individual publisher’s site, but also to provide a single channel through which the consumer can opt out across all other sites served by third parties that participate in the digital ecosystem.

Specifically, the DAA guidance and tools will include the following elements:

  1. A text link and new green icon for publishers to display on their web and app-based digital properties.
  2. The text link and icon will take users to a publisher-hosted notice that will provide user information and control, including either or both of the following, as needed:
    • If the publisher itself collects and sells personal information, the publisher’s page should include a mechanism that allows users to opt out of the publisher’s sale of that data.
    • If any third-party businesses collect information through a publisher’s digital property and sell that personal information, the page should include a link to the cross-industry CCPA Opt-Out Tool provided by DAA.
  3. The CCPA Opt-Out Tool will allow users to opt out of the sale of their personal information by any or all of the participating companies in the new DAA tools, including third parties collecting and selling personal information through the publisher’s site or app.

As outlined above, the intention is to provide a “one-stop shop” for consumers to exercise their opt-out rights under the CCPA within the DAA ecosystem. The tools will provide a mechanism for publishers to provide the opt-out right to California consumers and to then communicate when a consumer has exercised this right. The self-regulatory guidelines then require that any downstream third party only use any of that consumer’s personal information for one of five limited purposes: 1) intellectual property protection; 2) compliance, public purpose and consumer safety; 3) authentication, verification, fraud prevention and security; 4) billing or product or service fulfillment; or 5) reporting or delivery. The DAA stated that it will be rolling out the tools, guidelines and technological specifications “over the next few weeks.”

The DAA announcement is the latest in an effort for advertising groups to address the impending requirements of the CCPA. As we have previously written, just last month the Interactive Advertising Bureau developed and released a draft for public comment of the IAB California Consumer Privacy Act Compliance (CCPA) Framework for Publishers and Technology Companies. The IAB draft framework, like the DAA’s self-regulatory guidelines and tools, are intended to help publishers, ad agencies and other companies involved in the digital advertising ecosystem comply with the CCPA.


Kristopher Kleiner

Adam Connolly

David Navetta

Posted by Cooley