McLean, VA – February 6, 2024 – BBB National Programs’ Digital Advertising Accountability Program (DAAP) has brought job search platform Indeed Inc. and employer-review platform Glassdoor LLC, which both operate under Recruit Holdings Co., Ltd., into compliance with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for online interest-based advertising (IBA).DAAP’s investigation into Indeed’s website, which was the result of a consumer complaint, revealed noncompliance with the DAA Principles’ Transparency Principle for first-party publishers like Indeed and Glassdoor who allow third parties to collect user browsing behavior for IBA purposes. Though the consumer complaint was related to Indeed, given that Indeed shares infrastructure with Glassdoor, DAAP conducted its investigation on both platforms.

Identified issues included links in the footer related to privacy and user control of data not linking users directly to information relevant to the company’s DAA or IBA-related obligations, descriptions of third-party IBA practices scattered throughout the policies instead of one cohesive place, and no statement of adherence to the DAA Principles. In the company’s mobile apps, DAAP discovered that enhanced notice (that is, a direct link to a clear disclosure of IBA practices) was also not present in the times or places prescribed in the Transparency Principle.  

Inquiry Response

In response to DAAP’s inquiry, Indeed and Glassdoor conducted comprehensive reviews for compliance with the DAA Principles, identifying areas for strengthening.

The companies collaborated with DAAP on the following:

Enhanced Notice for Website Data Collection

  • Updated website footer links: Indeed’s “Privacy Center” now reads “Privacy Center and Ad Choices,” and Glassdoor’s “Privacy & Cookies” is now “Privacy & Ad Choices”
  • Added an “Ad Choices” tab to the HR Tech Privacy Center landing page, directing users to a consolidated IBA-specific disclosure

 

Cross-App Data Collection Compliance

  • Authorized third-party collection in their mobile apps
  • Added an “Ad Choices” website header tab on the HR Tech Privacy Center landing page to their privacy policies, ensuring easy access to the IBA disclosure from app store pages within two clicks
  • Enabled users to view the Ad Choices page within the application through privacy settings

 

In their respective statements, the companies provided:

  • Indeed: We are committed to the success of job seekers and employers and strive to be transparent about our privacy policies and practices. We appreciate the opportunity to participate in DAA’s Accountability Programs and their commitment in helping us comply with their Self-Regulatory Principles for Online Behavioral Advertising.
  • Glassdoor: Glassdoor is committed to the success of our users and strives to be transparent about our privacy practices with both job seekers and employers. We appreciate the opportunity to participate in DAA’s Accountability Programs and their commitment in helping us comply with their Self-Regulatory Principles for Online Behavioral Advertising.

 

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of DAAP decisions, visit the DAAP Decisions and Guidance webpage.

 

About BBB National Programs: BBB National Programs, a non-profit organization, is the home of U.S. independent industry self-regulation, currently operating more than a dozen globally recognized programs that have been helping enhance consumer trust in business for more than 50 years. These programs provide third-party accountability and dispute resolution services that address existing and emerging industry issues, create a fairer playing field for businesses and a better experience for consumers. BBB National Programs continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-and-teen-directed marketing, data privacy, dispute resolution, automobile warranty, technology, and emerging areas. To learn more, visit bbbprograms.org. 
 
About the Digital Advertising Accountability Program: The Digital Advertising Accountability Program (DAAP), a division of BBB National Programs, was developed by the Digital Advertising Alliance (DAA) to enforce industry self-regulation principles for data privacy in online and mobile advertising, holding companies accountable to the DAA’s Privacy Principles. DAAP provides guidance to companies looking to comply with industry principles and responds to complaints filed by consumers about online privacy. 

Contact:
Jennie Rosenberg
Media Relations
BBB National Programs
[email protected]