DMA Submits Comments on California AG's Tracking Transparency

This week, DMA submitted comments to the California Attorney General’s Office of Privacy Education and Policy on its draft document proposing “best practices” for transparency in the practice of online tracking. The draft proposal called for obligations beyond those required by newly-enacted AB 370, legislation requiring disclosure about certain information collected from consumer online activities.

DMA’s comments highlight the proposal’s divergence from the new law, underscore the need for clarity in this area and suggest referring to the document as “recommendations” rather than “best practices” to distinguish between what is and what is not required under the law. The Attorney General’s office has signaled that the finalized document will be consolidated with previously published recommendations on aspects of privacy policy statements: Privacy on the Go, Recommendations for the Mobile Ecosystem, and Recommended Practices on California Information-Sharing Disclosures and Privacy Policy Statements.

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