Don't Get Your Wires Crossed When Cross-Device Tracking

Shortly after FTC staff published the results of their study on cross-device tracking (described in this prior blog post), the FTC issued its own comprehensive report on the topic. In addition to highlighting many of the same benefits and privacy concerns raised by cross-device tracking, the FTC report provides an update on industry self-regulatory efforts in this area, along with practical recommendations for those involved in cross-device tracking, based on learnings from past FTC enforcement actions.

Self-Regulatory Efforts

In its report, the FTC praises the steps that have been taken by the National Advertising Initiative (the "NAI") and the Digital Advertising Alliance ("DAA") to address cross-device tracking thus far, but also notes certain areas that could benefit from clarification from both organizations.