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July 12, 2016
The Advertising Association’s response covers the following principles:
- Relevance and objectives: the GDPR means that elements of the e-Privacy Directive are now superfluous, the AA says. Some provisions however are useful to retain where they provide for flexibility, such as the soft opt-in exemption for email;
- Scope: there is no need to re-open the debate over areas that are already within the scope of the GDPR, the AA says;
- Online identifiers including cookies: the European Commission must not be allowed to determine business models, the AA says. The solutions proposed (e.g. obligation to provide a service in return for payment) would undermine the advertising industry;
- Consent: maintain the status quo, the AA says. Social media would be covered under the GDPR;
- Consistency with the GDPR: strip out areas where there is duplication with the GDPR; and
- Enforcement: enforcement must lie with the Data Protection Authorities, the AA concludes.
To access the AA’s full response, click here.