Public Policy Updates

How Ad-Tech Companies Help Bolster Small Publishers and Advertisers

[posted Sept 20, 2023; last updated Dec 18, 2024] Ad-Tech companies play an important role in helping small publishers and advertisers serve appropriate ads to consumers while maintaining and adhering

NAI Comments on DOJ Rulemaking on Data Brokerage and Bulk Sensitive Data

On November 29, the NAI submitted comments in response to the Department of Justice (DOJ) Proposed Rulemaking (NPRM) to regulate transfers of Americans’ sensitive data to foreign adversaries. The draft

NAI Comments on Proposed Amendments to the Colorado Privacy Act Rules

On November 7, 2024, the NAI submitted comments to the Colorado Department of Law in response to its Request for Comment on the proposed draft amendments to the Colorado Privacy

NAI Comments on NY Child Data Protection Act NPRM

On September 30, the NAI provided comments on the Office of the New York State Attorney General (“OAG”) Advanced Notice of Proposed Rulemaking (“ANPRM”) to assist the office in crafting

NAI Comments on CA Data Broker Registration Regulations

On August 20, the NAI submitted comments on the proposed California Data Broker Registration Regulations to the California Privacy Protection Agency (CPPA). In Section I, our comments recommend that the

NAI Sends Letter to House Energy and Commerce Committee Opposing APRA, Recommending Further Amendments

On June 25, the NAI sent a letter to the House Committee on Energy and Commerce urging the Committee to continue working to further improve the American Privacy Rights Act

NAI Preliminary Comments to CPPA re: Data Broker Deletion Registry

On June 25, the NAI submitted preliminary comments on the California Privacy Protection Agency’s (CPPA) proposed rulemaking to implement the Data Broker Delete Requests and Opt-Out Platform (“DROP”). As a

NAI: APRA should focus on preserving beneficial uses of data, and protecting consumers from harm

Welcomes a bipartisan, bicameral effort to enact a uniform national privacy framework On April 17, the NAI sent a letter to the U.S. House Committee on Energy and Commerce welcoming

NAI Sends Letter to CA Judiciary Committee in Support of Delete Act Amendments

On April 16, the NAI sent a letter to California Judiciary Committee stating our support of SB 1076, legislation to provide narrow but important updates to the California Delete Act, while

NAI Welcomes Bipartisan, Bicameral Effort to Enact a Uniform National Privacy Framework

Efforts should focus on preserving beneficial uses of data, and protecting consumers from harm WASHINGTON, DC (April 9, 2024) – The Network Advertising Initiative (NAI) released the following statement from

NAI Comments on COPPA NPRM

On March 11, the NAI submitted comments on the FTC’s (Federal Trade Commission) Notice of Proposed Rulemaking (“NPRM”) to amend the COPPA Rule (Children’s Online Privacy Protection Rule) pursuant to

NAI Submits Comments to CFPB on Financial Advertising

On December 29, 2023 the NAI submitted comments on the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) Notice of Proposed Rulemaking (“NPRM”) and the Proposed Rule on Personal Financial Data

NAI Comments on Colorado Universal Opt-Out Shortlist

On December 11, 2023 the NAI submitted comments on the Universal Opt-Out (UOOM) shortlist recently announced by the Colorado Department of Law (DoL). In summary, the NAI recommends the following

NAI Comments on NTIA Kids Online Health and Safety RFC

On November 16, the NAI commented on the National Telecommunications and Information Administration’s (NTIA) Request for Comment (RCF) on best practices to protect minors’ mental health, safety, and privacy online.

NAI Comments on Health Data Privacy RFI

On September 28, the NAI commented on Sen. Bill Cassidy’s (R-LA) Request for Information (RFI) on Improving Americans’ Health Data Privacy. The comments highlight three key recommendations: (1) Congress should

NAI Legal and Regulatory Analysis: Sensitive Health Information

Health-related advertising has been around nearly as long as advertising itself. However, new data collection and storage technology has fundamentally changed how many in the industry operate and the ways

NAI Comments on FTC Notice of Proposed Rulemaking to Update HBNR

On August 8, the NAI submitted comments to the Federal Trade Commission in response to their Notice of Proposed Rulemaking to update the agency’s Health Breach Notification Rule (HBNR). NAI’s

NAI Comments on CFPB RFI

On July 14, 2023 the NAI sent its comment on the CFPB RFI to the agency. These comments discuss the following key issues raised by the RFI, and make recommendations

State Privacy Patch #6 for Iowa: What Digital Advertising Companies Need to Know

By Meaghan Donahue (meaghan@thenai.org) and Ryan Smith (ryan@thenai.org) On March 29, 2023, Iowa Governor Kim Reynolds signed Senate File 262 (SF 262) into law, making Iowa the sixth state to

NAI Comments on the Comments on the CCPA’s Preliminary Rulemaking on Cybersecurity, Risk Assessments and Automated Decisionmaking

The NAI would like to thank the California Privacy Protection Agency for the opportunity to provide comments on the CCPA’s preliminary rulemaking on cybersecurity, risk assessment and automated decisionmaking. Please

NAI Comments on the Washington My Health My Data Act

The NAI would like to thank you for the opportunity to provide feedback on H.B. 1155, the Washington My Health My Data Act. Please see our full testimony below.

NAI comments to NTIA RFC on Privacy, Equity and Civil Rights

The Network Advertising Initiative (NAI), would like to thank the National Telecommunications and Information Administration (“NTIA”) for the opportunity to provide comments on the intersection of privacy, equity, and civil

NAI Comments on the FTC Petition for Rulemaking to Regulate Programmatic Advertising.

Thank you to the Federal Trade Commission for the opportunity to comment on the “Petition For Rulemaking Under 15 U.S.C. § 57(a) Seeking Regulation Of Advertising Technology Companies And Agencies

NAI Submits Testimony on Washington H.B. 1155

We want to thank the Washington State House Civil Rights and Judiciary Committee for the opportunity to provide feedback on H.B. 1155, the Washington My Health My Data Act.

NAI Comments on Version 2 of the Colorado Privacy Act

The Network Advertising Initiative (“NAI”) appreciates the opportunity to comment in response to Version 2 of the Proposed Draft Rules (“Revised Draft Rules”) for the Colorado Privacy Act(“CPA”).

NAI Submits Comments To The FTC ANPR

We want to thank the Federal Trade Commission for the opportunity to comment on the Advanced Notice of Proposed Rulemaking (“ANPR”) for a Trade Regulation on Commercial Surveillance and Data

NAI Comments on The Modified Proposed CPRA Regulations

The Network Advertising Initiative (“NAI”) appreciates the opportunity to provide comments on the proposed modified regulations under the California Privacy Rights Act(“CPRA”).

NAI Comments on CPA Proposed Draft Rules

On behalf of the Network Advertising Initiative, thank you for the opportunity to providepreliminary comments on proposed rulemaking under the Colorado Privacy Act.

NAI Comments on Proposed Regulation Under the CPRA

The NAI comments call on the California Privacy Protection Agency to amend their proposed regulations regarding the use of Opt-out Preference Signals, which could be used to unfairly disadvantage businesses across

Prepared Remarks for CPA Pre-Rulemaking Listening Session

The NAI’s Vice President of Public Policy, David LeDuc, delivered remarks at a Colorado Privacy Act pre-rulemaking listening session held by the Colorado Attorney General’s Office. We emphasized the importance

NAI Preliminary Comments on Proposed Rulemaking under the Colorado Privacy Act

The NAI submitted comments to the Office of the Attorney General (OAG) in Colorado on proposed rulemaking under the Colorado Privacy Act. The NAI supports the OAG in its principle-guided

NAI Comments to NTIA on Competition in Mobile App Ecosystem

In comments to the NTIA on the Report on Competition in the Mobile App Ecosystem, the NAI recommended a balanced approach to privacy and competition, focused on eliminating harmful or

Best Practices for User Choice and Transparency

This Resource, developed by NAI legal and policy staff in consultation with representatives from member companies, is intended to help member companies better understand the practice of dark patterns and

Prepared Remarks for CPPA Stakeholder Session

The NAI’s VP of Public Policy, David LeDuc, joined the CPPA for a stakeholder session prior to the development of draft implementing regulations for the CPRA. We urged the CPPA

NAI Regulatory Summary and Analysis: Statement of the Federal Trade Commission on Breaches by Health Apps and Other Connected Devices

The NAI has published a Regulatory Summary and Analysis in response to the FTC’s September 2021 Policy Statement on the Health Breach Notification Rule, and its recent guidance updated in

NAI Comments: Petition for Rulemaking to Prohibit Surveillance Advertising

The NAI filed comments with the Federal Trade Commission (FTC) in response to a petition proposing an FTC rulemaking on unfair competition that would result in a ban on “surveillance

Prepared Remarks from NAI President & CEO Leigh Freund for NTIA Virtual Listening Session on Personal Data: Privacy, Equity, and Civil Rights

On behalf of the Network Advertising Initiative (“NAI”), President & CEO Leigh Freund joined a virtual listening session hosted by the National Telecommunications and Information Administration (“NTIA”) to discuss solutions

NAI Comments: The Washington State Public Disclosure Commission (“PDC”): How to Improve Digital Political Advertising Disclosure in the State

The Network Advertising Initiative (“NAI”) appreciates the opportunity to provide comments on the Washington State Public Disclosure Commission deliberations on how to improve digital political advertising.

Preliminary Comments on Proposed Rulemaking Under the California Privacy Rights Act

On behalf of the Network Advertising Initiative (“NAI”), thank you for the opportunity to providepreliminary comments on proposed rulemaking under the California Privacy Rights Act (“CPRA”).

NAI Comments: Bringing Dark Patterns to Light: An FTC Workshop

At a time when Americans are spending more time than ever on connected devices, this discussionabout “dark patterns” is important and timely. While there are different definitions of this term,

Public Policy Leadership for Ad-Tech Companies

The Network Advertising Initiative (NAI) is the leading ad-tech industry association, helping member companies navigate the increasingly challenging legal and regulatory environment. The NAI’s advocacy program also promotes and protects

Testimony on WA SB 5062 (Washington Privacy Act of 2021)

On behalf of the ANA, the 4A’s, the AAF, the IAB, and the NAI, thank you for the opportunity to provide comments on SB 5062 (“WPA”). In addition to this

NAI Letter to Rep. Schiff Regarding Ad Blocking on News Sites

On behalf of the Network Advertising Initiative (NAI) and our members, thank you for your recent inquiry about digital advertising practices during the COVID-19 pandemic and the potential negative effects

NAI Summary of CPRA

This summary represents the NAI’s preliminary analysis of the changes to the CCPA proposed by the CPRA ballot initiative. This summary is intended only to highlight proposed changes of particular

Political File Requirements- Presentation by Perkins Coie

NAI Comment Letter – CCPA Second Set of Modified Regulations

The Network Advertising Initiative (“NAI”) is pleased to submit these comments regarding the second set of modifications to the regulations proposed for adoption under the California Consumer Privacy Act of

NAI Comment Letter: COPPA Rule Review

NAI Comment Letter: COPPA Rule Review

On behalf of the Network Advertising Initiative (NAI), thank you for providing the opportunity to revisit the crucial priority of protecting children on the internet. NAI submits these comments in

NAI Analysis – CCPA Sales

Considerations for NAI Members Regarding the Classification of Ad-tech Data Flows as “Sales” Under the CCPA: An NAI Analysis

CCPA Amendment Summary

NAI Analysis of Verifiable Consumer Requests under the CCPA

This analysis will explain the rights California consumers have gained under the CCPA to request access to and deletion of their personal information, and how businesses are required to verify

NAI Comments to California AG Xavier Becerra re: CCPA Regulations

The Network Advertising Initiative (“NAI”) is pleased to submit this letter in response to the Department of Justice’s request for comments regarding implementing regulations it may promulgate under the California

NAI Comments to FTC re: Consumer Privacy Hearings

Thank you for to opportunity to submit comments in advance of the upcoming hearing on Consumer Privacy, scheduled for February 12-13. Please find below detailed responses to the questions for

NAI Comments to NTIA re: National Privacy Framework

Thank you for providing this thoughtful, comprehensive approach to enhancing consumer privacy and balancing the need to promote robust innovation, and for the opportunity to comment. The NAI concurs that