Browse F.A.Q. Topics
- 1 – About EDAA2
- 2 – European Principles7
- 3 – OBA Icon & Consumer Choice Platform11
- 4 – Licensing Process2
- 5 – Certification Process6
- 6 – SRO’s, Consumer Complaint Handling & Potential Sanctions5
- 7 Consumer Awareness and Attitudes1
- 8 – Benefits for Participating Companies1
- 9 – Global Self-Regulatory Landscapes & The Legal Context3
- Further Information1
1 – About EDAA
The European Interactive Digital Advertising Alliance empowers consumers with greater transparency, choice and control, and provides the tools for businesses to enable that to happen.
EDAA is responsible for the administration of the pan industry self-regulatory programme on Online Behavioural Advertising (OBA), enabling consumers, through the display of an icon, to access transparency and choice with regard to OBA. EDAA provides this Icon to companies involved in Online Behavioural Advertising across Europe. Read more About EDAA.
2 – European Principles
The European Principles documents include
- The IAB Europe OBA Framework serves to codify industry self-regulatory standards for Online Behavioural Advertising in Europe, highlighting a set of key principles that participating companies must adhere to.
- The EASA Best Practice Recommendation on OBA builds on this Framework by providing guidance to national advertising Self-Regulatory Organisations, under the umbrella of the European Advertising Standards Alliance (EASA), to apply credible complaint handling and sanctions mechanisms, ensuring the accountability of the Programme.
- The Technical Specifications for Implementing the IAB Europe OBA Framework and EASA BPR in Europe details how companies should technically apply the OBA Icon to online ads and how to avoid collision of overlays being applied at different stages in the ad delivery process.
Over several years, the Programme and principles have also expanded, for instance into the mobile and video advertising spaces, to keep pace with evolving market technologies and consumer use trends. As such, the European Principles have built upon the initial Framework and BPR, to include today:
- The Self-Certification Criteria for Participating Companies,
- Application of the Principles in the Mobile Environment,
- Ad Marker Implementation Guidelines for Mobile,
- Ad Marker Implementation Guidelines for Video.
It is important for companies to review each of the aforementioned European Principles documents and implement the appropriate practices to ensure full compliance with the self-regulatory approach.
The European Principles focus on the practice of Online Behavioural Advertising and do not cover:
- Strictly “first party” OBA – i.e. OBA data collection and use by a website operator, across their own website(s). Website operators are nevertheless strongly advised to sign up and use the AdChoices Icon in order to provide ‘adequate disclosure’ to consumers where OBA may be happening by third parties acting across their website(s);
- Contextual advertising (display advertising which is delivered based on the context/content of the page where it is displayed);
- Ad delivery and ad reporting (as defined in the European Principles).
While the European Principles are intended to apply broadly across a wide range of marketing and media entities, they focus on:
- “Third Parties” such as advertising networks and data companies (including data aggregators) and in some cases advertisers;
- “Website Operators” such as publishers and advertisers.
These types of entities work interdependently to deliver relevant advertising to specific computers or devices in ways that enrich the consumer online experience. The Principles also cover technologies that are intended to collect all or substantially all URLs (websites) that a PC (or any other device) traverses and uses such data for interest-based advertising. This could include tools and software like toolbars, desktop applications, ISP-based technologies, etc.
Companies must fulfill their specific obligations under the European Principles related to the particular role(s) of each company in collecting and/or using data for interest-based advertising purposes.
Your obligations under the European Principles differ depending on your role in the European online digital advertising ecosystem. For more information, companies should refer to the European Principles documents and self-certification criteria.
All companies acting as third parties (as defined in the European Principles) who are engaged in the use of OBA data in order to deliver ads must sign up to use the AdChoices Icon from EDAA. All companies engaged in the collection of OBA data must participate in the Consumer Choice Platform. In order to obtain the relevant services agreements, please apply here.
Website Operators may voluntarily participate to use the AdChoices Icon and there are many benefits in doing so (see Q8 of these FAQs for more information). Website Operators should also ensure that all of the third parties involved in interest-based advertising they work with are participating in the European Self-Regulatory Programme and are compliant with the European Principles. Participating companies can be viewed here. Advertisers and agencies will also be able to recognise compliant “third party” partners by the EDAA ‘Trust Seal’, which will be awarded to companies following an independent compliance assessment and ongoing monitoring of their interest-based advertising practices – see Section 5 of these FAQs.
Acting as a first-party, you are under no obligations to use the AdChoices Icon. Under the European Principles, first parties must provide ‘adequate disclosure’ to consumers and may voluntarily apply to use the AdChoices Icon to use in footer links, if they wish to do so.
Though it is voluntary, using the AdChoices Icon has many benefits for first parties, as consumers recognise the AdChoices Icon and associate it with enhanced privacy standards. Put simply, website operators will reap rewards of increased consumer trust and therefore use of the AdChoices Icon could lead to increased consumer interaction with your website.
- If you are collecting OBA data as a Website Operator for advertising or retargeting across websites under your Common Control (i.e. which you own and operate over 50%), then there is no need to integrate onto the “YOC” Consumer Choice Platform.
- If you are collecting OBA data from third party websites (either directly or through a technology provider) for use across your own websites, or if using OBA data collected from across your own websites for advertising or retargeting on third party websites, then you are effectively acting as a Third Party and would be required to integrate onto the “YOC” Consumer Choice Platform, in order to give consumers the choice and control over this type of targeting. The latter would be considered as a form of Third-Party OBA.
The European Principles are designed as ‘technology-neutral’. As such, EDAA has released a set of principles covering mobile considerations, including the use of cross-app, precise location and personal directory data. For this environment, EDAA has released clear technical specifications for serving the AdChoices Icon across mobile ads (which applies to both mobile browser and mobile in-app), which can be consulted here. As yet, participating companies are not required to implement a mobile AppChoices platform for in-app choice under the European SR Programme.
However, all participating companies are required to respect the choices made by a consumer through alternative means (for instance, via the mobile device settings, application settings, or a company owned app-specific choice platform). Icon use in the mobile environment, as well as choices conducted through the web browser are considered components of the independent certification required under the Programme.
3 – OBA Icon & Consumer Choice Platform
The AdChoices Icon is a consumer-facing, interactive tool, symbolising consumer transparency, choice and control over interest-based advertising.
It is an interactive symbol to be placed in or around online ads (by “Third Parties”), or on websites where OBA data may be collected and/or used (by “Website Operators”) and demonstrates that companies involved in serving the ads are respecting the self-regulatory principles in a way that empowers consumers. The AdChoices Icon increases consumer and marketer trust in interest-based advertising by linking through to consumer-friendly information about interest-based and online advertising, including the information portal and Consumer Choice Platform YourOnlineChoices.eu.
The AdChoices Icon must always provide a clear and prominent link through the “YOC” Consumer Choice Platform. This Platform ensures that the consumer is offered a clear and easily accessible choice and control mechanism over interest-based advertising, by some or all participating companies. The Platform is hosted on the website YourOnlineChoices.eu, administered by EDAA. This website (currently available in 33 country-specific versions and 27 different European languages) serves as a one-stop-shop for consumers, offering: (a) clear information about online and personalised advertising; (b) a mechanism to enact meaningful choice and control; and (c) a portal to file any consumer feedback or complaints with the national advertising Self-Regulatory Organisation (SRO) – see Section 5 of these FAQs.
Companies may also provide their own company-specific opt-out mechanisms; however, these must be in addition and complementary to participation on the “YOC” Consumer Choice Platform, which serves as a pan-European, one-stop-shop for consumer information, choice and control regarding interest-based advertising across Europe.
All companies involved in actively using OBA data to deliver online display, mobile or video advertising should participate via a service agreement to use the AdChoices Icon.
Third Parties: for instance, ad networks, technology platforms, data aggregators, Demand Side Platforms (DSPs) and Supply Side Platforms (SSPs). To clear any doubt, retargeting is considered as Third-Party OBA covered by the European Principles.
Website Operators (voluntarily): advertisers and publishers across sites under their Common Control (owned and operated by the same company).
It is the full responsibility of a company to hold a valid service agreement from EDAA for such use, regardless of how the integration is done (via an Approved Icon Provider or in-house).
Since the Ad Network is collecting and using OBA data on your behalf, each ad they place on your behalf must carry the AdChoices Icon, for which the licensing obligation sits with the Ad Network.
Many advertisers, however, prefer to manage the placement of the AdChoices Icon centrally via their Ad Agency and/or Ad Server to provide for more branded control of the messaging and in some cases reporting.
If you choose to manage this directly via your Ad Server or Ad Agency, the obligation to obtain the AdChoices Icon directly from EDAA sits directly with you, and you cannot use the AdChoices Icon via your Ad Server or Ad Agency without the right for your company to use it from EDAA.
All companies involved in actively collecting OBA data, which may be used to then deliver online display, mobile or video advertising based on this data, should register to integrate onto the “YOC” Consumer Choice Platform, to provide consumers with the choice and control over their data collection. This also includes where data may be collected for retargeting purposes.
There are specific guidelines as to how the AdChoices Icon should be integrated on online advertising (types of ads, size, colour, etc.). These are specified in the Technical Specifications for implementing the IAB Europe OBA Framework and EASA BPR on OBA in Europe, as well as some further rights of use (and limitations) as detailed in the appropriate service agreement which can be requested from EDAA by applying through the online form.
In order that companies can effectively deploy the AdChoices Icon on their campaigns, EDAA has approved two commercial providers offering icon integration services: Evidon and TrustArc. We recommend the services of these providers and more information can be found here.
The AdChoices Icon should be used as described in the Technical Specifications for implementing the IAB Europe OBA framework and EASA BPR in Europe.
Particularly, the AdChoices Icon should not be used for any other purpose/business need other than ensuring compliance with the European Principles and offering consumers the transparency and choice that the Icon represents.
Use of the AdChoices Icon and “YOC” Consumer Choice Platform is afforded to companies who have signified a commitment to the European Principles and signed the appropriate service agreement(s) with EDAA.
No company may use the AdChoices Icon in Europe or integrate onto the Consumer Choice Platform without a valid service agreement from EDAA.
The Tariff Schedule is consistent for all participating companies and annexed to the corresponding EDAA service agreements. In brief, the fees are applied per calendar year, and are set at 5.000 EUR for each service.
In order to ensure that no company is ‘priced out’ of the Programme, EDAA also provides a 40% discounted rate for SMEs – 3.000 EUR per service. Is considered an SME any company with less than 3 million EUR in annual revenue from all online display, mobile and video advertising.
EDAA is an international non-profit organisation and the fees applied are designed to ensure that the European Self-Regulatory Programme can run effectively across all EU and EEA markets. The fees support operational aspects of the Programme such as an effective administration, development and maintenance of multiple websites including the monitoring and functioning of the Consumer Choice Platform, as well as integration with well-established Self-Regulatory Organisations (SROs) for complaint handling across Europe and initiatives to build consumer understanding and awareness (such as a consumer awareness campaign and various related research projects).
EDAA has been established to administer the European Self-Regulatory Programme and in particular services for the AdChoices Icon and the “YOC” Consumer Choice Platform to any company practising interest-based advertising within Europe.
As such, participation is done directly with EDAA and no company is required to be a member of any governing association or other industry trade or self-regulatory organisation in order to participate. Any company within Europe may apply directly to EDAA for use of the AdChoices Icon and may integrate onto the “YOC” Consumer Choice Platform.
If you would prefer to contact a national-level organisation, local IABs and SROs (self-regulatory organisations) would be pleased to assist you. For contact details of your national IAB, please visit IAB Europe. For contact details of your national SRO, please visit the EASA website.
4 – Licensing Process
Having perused the European Principles documents, please apply for the AdChoices Icon and “YOC” Consumer Choice Platform via our online form.
If you have any questions prior to applying, which may not be covered in the European Principles or these FAQs, please contact us at: info [at] edaa [dot] eu.
Once the online application form has been submitted, you will receive an automated response to know that this has been received by EDAA. We will contact you further – usually between 1-3 working days – with a recommendation on how best to move forward within the Programme and will provide the appropriate services agreements, depending on your company’s business model.
There are separate services agreements for:
- Website Operators using the AdChoices Icon in order to provide ‘adequate notice’ of OBA data collection and use by third parties permitted on their sites;
- Third Parties using the AdChoices Icon in order to signal their OBA practices in a contextual (in-ad) manner to consumers;
- Third Parties using the “YOC” Consumer Choice Platform to provide consumers with choice and control over the collection and use of OBA data.
The corresponding service agreements are provided on a “fixed-form” basis. Once signed, EDAA will provide a package of further information (including icon creatives with accompanying texts for all markets; technical guidelines for “YOC” integration) and further details with regard to next steps in the Programme (self-certification and independent compliance assessment), and will support you through each step of your integration.
5 – Certification Process
Purpose: a ‘declaration’ of compliance to EDAA once the company is satisfied that they are fully adhering to the European Principles.
Timeframe: six months. All companies having joined the Programme will have 6 full months to complete the self-certification. Self-certification must be completed prior to the next step – an independent certification assessment and ongoing monitoring by an EDAA-approved Certification Provider. Companies not completing the self-certification within this timeframe will be considered to be in breach of the Programme, and EDAA may take appropriate action (i.e. withdrawing company use of the AdChoices Icon and/or integration on the “YOC” Consumer Choice Platform).
Further information: please have a look at the self-certification criteria and the online form through which companies must submit their self-certification (this may also be submitted in PDF, if preferable). Once this form has been submitted, a copy is sent electronically to EDAA and a second copy is sent to the company (to the email address submitted on the form). Companies should retain their copy of the self-certification, as this may be requested at a later stage by their chosen Certification Provider in order to validate the information as part of completing the independent compliance assessment.
All participating companies are required to self-certify, though “Website Operators” have a significantly limited criteria, covering only the “adequate disclosure” requirement as outlined in the European Principles, respecting the different roles between Third Parties and Website Operators within the Programme.
Purpose: to complete an independent assessment of compliance and obtain the corresponding “trust seal”.
Companies can choose from a range of EDAA-approved Certification Providers in order to fulfil the further compliance obligations: an independent compliance assessment and continuous monitoring of compliance related activity. All approved providers to-date offer an annual assessment of compliance.
Timeframe: within 8 months of signing up. Companies not completing the independent compliance assessment within this timeframe will be considered to be in breach of the Programme, and EDAA may take appropriate action (i.e. withdrawing company use of the AdChoices Icon and/or integration on the “YOC” Consumer Choice Platform).
Further information: in order to help ensure a competitive market, EDAA has approved several providers. As the process must be handled independently of EDAA, exact pricing and assessment methodologies should be agreed directly between the company and the Certification Provider.
Certification Providers are required to apply the certification services in an independent manner (from industry and other services). All approved Certification Providers have verified this independence to the satisfaction of EDAA. Where a Certification Provider is also providing other services within the European Self-Regulatory Programme (such as acting as an approved Icon Provider), EDAA has deemed that these services are being performed in a manner demonstrating a clear separation of internal business processes.
Topline: the ‘Trust Seal’ (pictured below) is a symbol of good standing, responsibility and trust towards the business community and consumers – demonstrating verified company compliance with the European Principles; it will be awarded once the company has self-certified and undertaken the compliance assessment, including an initial 30 days of uninterrupted ongoing monitoring of compliance by an approved Certification Provider (see FAQ 26 below). EDAA “Trust Seal” will be hosted by the company’s chosen Certification Provider (with back-end validation mechanisms) to be displayed on the compliant company’s website.
Timeframe: 8 months. The company should obtain the Trust Seal within 8 months of signing up to the Programme. This comprises of the 6 months for self-certification, an additional month for compliance assessment, and a further 30 days of ongoing monitoring prior to award of the Trust Seal. The Trust Seal is then subject to monitoring of compliance and must be renewed every 2 years from the date of issue (N.B. the validity of a Trust Seal has been extended from 1 year to 2 years as of 1 June 2018, to improve the certification process and services for the benefit of all participating companies).
EDAA has appointed four Certification Providers: ABC, BPA WorldWide, ePrivacy and TrustArc. Further information, including contact details of approved Certification Providers, can be found here. As the process must be handled independently of EDAA, exact pricing and assessment methodologies should be agreed directly between the company and the Certification Provider.
Yes. EDAA will offer visibility and recognition to those companies progressing proactively towards their compliance obligations within the Programme. In order to incentivise companies to undergo the compliance and certification process sooner rather than later, the stage that companies have obtained will be made public and visible in EDAA's
Activity Reports, and on an ongoing basis directly on EDAA websites (list of participating companies and YourOnlineChoices.eu).
Yes, as of 1 January 2019, companies are required to deliver the AdChoices Icon also on online video ads.
6 – SRO’s, Consumer Complaint Handling & Potential Sanctions
Self-Regulatory Organisations (SROs) are independent bodies set up by the ad industry to apply advertising codes of practice. In the case of OBA, the EASA Best Practice Recommendation on OBA details how SROs are responsible for consumer complaint handling on OBA.
SROs, where their remit has extended to cover OBA, apply clear, user-friendly and accessible mechanisms for consumers to file complaints on allegedly non-compliant businesses. These mechanisms are accessible either directly through the website of the national SRO, or through YourOnlineChoices.eu.
SRO processes, specifically investigations and sanctions (where appropriate), are tailored to an OBA context. This ensures effective enforcement of the rules in a coherent and consistent manner. SROs apply national codes, though these codes on OBA reflect the European Principles. A full list of SROs, as well as contact details, can be found on the website of the European Advertising Standards Alliance (EASA).
In order to ensure upmost consistency for businesses and consumers, only one specific SRO will contact any single company regarding a complaint against that company’s OBA practices. The SRO will be determined by the company’s designated “Country of Origin” when signing the appropriate services agreement(s) with EDAA, upon joining the Programme. Each company must ‘self-designate’ an SRO based on their Country of Origin, according to specific criteria, which ensure that the company designates a European country where it has an office with a competent decision-making presence.
In cases where your company has no European office, or it is unclear where the most appropriate country to designate would be, you should discuss this directly with EDAA prior to signing the service agreements.
SROs follow consistent procedures for complaint handling (informal resolution; investigations; adjudications) and when applying appropriate sanctions. If you have any questions not covered here regarding the roles and processes of SROs, please contact us at: info (@) edaa.eu.
The SRO in the ‘country of origin’ of the company will handle a relevant consumer complaint. However, the SRO in the country of the consumer will be responsible to inform the consumer of the status and outcome of their complaint in their local language.
EDAA reserves the right to refuse or revoke any agreement for the use of the AdChoices Icon and/or “YOC” Consumer Choice Platform in Europe, if it deems that these services are being misused, or in order to protect the integrity of the Programme for the benefit of all participating companies. This will be done only after warning the company of their misuse and providing a small grace period to rectify the issue. If a company has their service agreement revoked, they will be able to reapply once EDAA is assured that the company has taken appropriate steps to prevent any further misuse.
Where appropriate, sanctions applied by national advertising SROs are based on an incremental approach and include (i) name and shame – i.e. publication of non-compliance; (ii) ad alert – i.e. informing the wider business community of non-compliance; (iii) removal of ‘Trust Seal’ used to signal compliance to the market; (iv) withdrawal of use of the AdChoices Icon/“YOC” Consumer Choice Platform; (v) as a last resort, referral to the relevant regulator. These sanctions would be applied based on an incremental process, considering the nature of a breach and whether or not it is deemed to be a serious, persistent and/or deliberate breach.
EDAA runs, from time to time, a pan-European consumer awareness campaign. This takes the form of online display ads, focused on several different creative concepts developed by Mediacom Beyond Advertising, where the AdChoices Icon is promoted clearly and prominently. The campaign, created and developed by EDAA, is supported and implemented in each national market by the local advertising ecosystem, including both companies and associations.
In terms of assessing consumer attitudes towards the Programme, the concept of interest-based advertising, and the players involved, EDAA also produces and partners with regular research projects to provide a clear and comprehensive overview of consumer attitudes, and how these change over time. In particular, EDAA research often focuses on consumer recognition and understanding of the consumer-facing tools (AdChoices Icon and YOC Consumer Choice Platform), as well as favourability towards the concept of personalised advertising and towards the brands being advertised. The existing evidence-base shows year-on-year improvements across each area and highlights that the European Self-Regulatory Programme administered by EDAA makes a clear difference towards empowering European internet users with meaningful transparency, choice and control. The latest report can be accessed here.
7 Consumer Awareness and Attitudes
There are countless benefits to companies that participate in the EDAA’s European Self-Regulatory Programme. Here are a few:
- Building/improving your brand image;
- Increasing responsibility and trust in advertising;
- Ever-increasing consumer awareness of the scheme;
- High visibility of participating companies;
- Recognition as being part of an industry-wide, pan-European, and increasingly global standard;
- Helping to actively ensure the future of personalized advertising as an essential element of your online marketing strategy!
8 – Benefits for Participating Companies
EDAA expects increasing consumer awareness of the Programme given the interactive, consumer-facing nature of the AdChoices Icon. The Icon is delivered on a mass scale, (159 billion impressions in 2018 alone). Consumers are inquisitive and are seeking more information through the user-friendly language and explanations offered on the YourOnlineChoices.eu. Information is provided in a variety of user-friendly ways and traffic to the site is consistently reaching approximately 2 million unique browser visits each month, demonstrating its role as an incredibly useful and popular consumer portal for information, choice and control.
Beyond high visibility of the AdChoices Icon, a consumer awareness campaign is also run periodically by EDAA.
It is also made clear to consumers which companies have signed up to the Programme through a range of measures. Firstly, company-owned and designed interstitial pages will enable company branding and visibility to be part of the interactive consumer experience. Moreover, lists and logos of participating companies will be displayed on both the YourOnlineChoices Consumer Choice Platform, as well as the EDAA’s website. For companies integrated onto the “YOC” Consumer Choice Platform there is also added visibility and credibility generated. Finally, a Trust Seal will be awarded to compliant signatory companies.
All the above and more ensure the exceptionally high visibility of the Self-Regulatory Programme and the continuously increasing amount of participating companies across Europe.
9 – Global Self-Regulatory Landscapes & The Legal Context
All companies collecting and/or using information for the purposes of interest-based advertising within Europe must sign up to the European Programme directly with EDAA, for use of the AdChoices Icon and YOC participation.
Companies should note that EDAA is responsible for administering the self-regulatory approach across all European Union (EU) and European Economic Area (EEA) countries, as well as Switzerland and Turkey. Markets beyond this are not currently within the geographic scope covered by EDAA and may apply other regulatory or self-regulatory requirements. It is the sole responsibility of each company to check and adhere to all applicable rules in any territories outside of Europe.
EDAA participation is pan-European and therefore covers the practice of OBA across Europe, in accordance with the European Principles. The European Principles place obligations on “Third Parties”, whilst “Website Operators” may use the Icon voluntarily alongside their obligation to provide ‘adequate disclosure’.
However, in some national contexts it may be necessary for companies to adhere to separate First Party frameworks. If so, a company should contact their national SRO (self-regulatory organisation) – visit www.easa-alliance.org to find your national SRO – or IAB (Interactive Advertising Bureau) – visit IAB Europe to find your national IAB – to find out if this is necessary. Currently only Germany requires companies to adhere to a national first party framework, and this is administered by the German Self-Regulatory Organisation, “DDOW”.
EDAA, through close collaboration with the Digital Advertising Alliance in the US, has worked to ensure that a single global Icon can be used across the US and European jurisdictions for purposes aligned with the European Principles. This has helped to ensure consistency in approach between the distinct self-regulatory environments for the benefit of businesses and consumers.
The Self-Regulatory Programme on OBA is complementary to applicable European and national law and should not be viewed as a substitute. The self-regulatory work seeks to offer internet users greater transparency and control over behavioural advertising. Many national-level governments explicitly support the initiative and industry remains engaged with the national regulators, European Commission, as well as consumer and civic society groups, as this initiative progresses. This approach recognises that each type of digital business has a role to play in achieving compliance, but that not one solution on its own may necessarily achieve this.
The Programme itself is a self-regulatory initiative aimed to foster transparency in the online advertising environment for all, through delivering consumer-facing information and control solutions with regard to how data is used for interest-based advertising. These solutions are self-regulatory in nature and correspond to industry best practice. They do not provide for or infer legal compliance (including with GDPR), which businesses themselves are responsible for, and should not be seen as such, though many companies may choose to adopt these self-regulatory tools as part of a broader ecology of statutory and self-regulatory solutions. The cross-industry self-regulatory initiative was developed by leading European bodies to introduce pan-European standards to enhance transparency and user control over data used for interest-based advertising. This type of advertising increasingly helps to support the cost of providing content free at the point of access to consumers, and a range of services and applications that internet users can enjoy at little or no cost. The self-regulatory initiative is based upon IAB Europe's OBA Framework and EASA's BPR on OBA.