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.