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Administrative Dispositions and Closures
Administrative Dispositions and Closures

Under its Procedures, the Accountability Program has sole discretion in initiating or disposing of formal reviews. One type of disposition is known as an Administrative Disposition. Administrative dispositions are issued when an inquiry determines:

- a company was not engaged in online behavioral advertising or multi-site data collection as defined by the Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data (collectively, the Principles);

- a company was already engaged in efforts to bring its practices into compliance with the Principles at the time the formal review was initiated.

An Administrative Disposition is a short document that states the nature of the inquiry and the reasons for its disposition. For Decisions, which provide more detailed guidance to industry on the Principles, please see the Decisions Page.

Additionally, in rare instances, the Accountability Program may choose to dispose of a formal review by means of Administrative Closure. Administrative Closures are numbered for the record, but the names of the companies involved are not publicly available. Below, you will find the list of Administrative Dispositions and Administrative Closures to date. Please click on the links below to see the full text of any Disposition or Closure.

Administrative Dispositions

MediaMind Technologies, Inc.: MediaMind, among other things, offers companies a self-serve platform for use as an ad serving platform. Initiative, a global media, marketing and digital agency, had secured the MediaMind ad platform on a self-serve basis to serve LifeLock OBA ads. MediaMind contractually required its clients to comply with the DAA’s OBA Principles as a condition of using its ad serving platform on a self-serve basis. MediaMind also provided its client with instructions and training regarding how to use the platform to serve the AdChoices Icon when required. When a company contractually requires compliance with the OBA Principles and provides training regarding use of the Icon in those ads which are served based on OBA data collection, then the client (here, Initiative) assumes the responsibility for compliance. The Accountability Program thus exercised its discretion to close the inquiry involving the self-serve platform by means of an Administrative Disposition. Read the disposition.
Volkswagen of America, Inc.Read the disposition.
Facilitate Digital Holdings: a provider of digital marketing technology and services, which agreed to follow the Accountability Program’s recommendation to change its opt-out cookie to the industry standard of five years but has not yet done so. Read the disposition.
Gravity: a provider of personalization tools for publishers, which has followed the Accountability Program’s recommendation and changed its opt-out cookie to the industry standard of five years. Read the disposition.
Rovion: an ad management platform for publishers and agencies, which has followed the Accountability Program’s recommendation and changed its opt-out cookie to the industry standard of five years. Read the disposition.

Administrative Closures

In Re First Party Enhanced Notice: Based on the following four factors, the Accountability Program has administratively closed formal reviews of seven companies whose websites did not provide enhanced notice of third-party data collection for online behavioral advertising (OBA): 1) each of the companies had longstanding compliance with all other requirements of the OBA Principles; 2) the enhanced notice requirement appears to have confused a significant number of companies; 3) there had been no prior FTC or industry best practice regarding this precise form of enhanced notice which is an innovation of the OBA Principles; and 4) each company promptly began working with the Accountability Program to implement its recommendations and has achieved or will soon achieve full compliance.Read the closure.