ANA Submits Comments following FTC Disclosures Workshop

November 2, 2016

In September, the Federal Trade Commission (FTC) held a workshop entitled “Putting Disclosures to the Test” at which participants examined how companies present their advertising claims, privacy practices, and other information to consumers. During the event, a number of researchers presented their findings on the advantages and disadvantages of different types of disclosures and various methods of assessing their effectiveness. The participants provided multiple perspectives, but there was no clear consensus on best practices. Nevertheless, a couple of presenters acknowledged the important role icons can play in presenting information in a meaningful way to consumers.

To help strengthen and supplement the record of this extremely important workshop, ANA and the Digital Advertising Alliance (DAA) supported the filing of supplemental comments to the FTC, provided by Howard Beales, Professor of Strategic Management and Public Policy at The George Washington University School of Business and a former director of the FTC Bureau of Consumer Protection. These comments discuss the multiple roles disclosures can play, and how FTC oversight and regulation should handle these questions. Professor Beales also discussed when and how testing should be carried out in regard to disclosure policy.

In addition, Professor Beales highlighted the important role that icons can play in notifying and providing disclosures to consumers about key product attributes or other relevant and important information such as those encapsulated in the DAA privacy icon. ANA will continue to work to actively bring enhanced clarity to the important issue of advertising disclosures, and we are hopeful that the FTC will continue to support the advertising industry’s self-regulatory efforts through the work of the DAA. We will keep the ANA legal representatives informed if there are further noteworthy developments in this area.


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