Warning: Upcoming Enforcement Action - CBBB Announces Compliance Deadline For Web Publishers

The Council of Better Business Bureaus ("CBBB") has issued a Compliance Warning letter announcing that, beginning January 1, 2014, the CBBB will commence enforcement actions against website publishers, operators, and other first parties that do not provide transparency with respect to data collected from visitors to their site and used by third parties for online behavioral advertising ("OBA") purposes. The CBBB operates an accountability program for enforcing the Digital Advertising Alliance's ("DAA") Self-Regulatory Principles governing the collection and use of web viewing data.

WHO IS COVERED. A first party, which is an entity that is the owner of a website or has control over a website with which a consumer interacts where data is collected or used by a third party (e.g., ad network) for OBA purposes.