2023-11-10T12:39:21-06:00 2022-12-31 521392008 GELMAN ROSENBERG & FREEDMAN 4550 MONTGOMERY AVE SUITE 800N BETHESDA MD 208142930 990 2022-01-01 522291538 NETWORK ADVERTISING INITIATIVE NETW 5713660500 409 7TH STREET NW 250 WASHINGTON DC 20004 LEIGH FREUND PRESIDENT & CEO 5713660500 2023-11-10 1 LEIGH FREUND 999009999 0 RICHARD J LOCASTRO CPA P00288314 3019519090 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z LEIGH FREUND 409 7TH STREET NW 250 WASHINGTON DC 20004 3873674 0 X WWW.NETWORKADVERTISING.ORG X 1999 DC SEE PART III, LINE 1. 12 12 8 18 0 0 0 0 3381650 3873674 0 0 2841 0 3384491 3873674 0 0 0 0 1718951 2057828 0 0 0 1425091 1578945 3144042 3636773 240449 236901 3040800 3363067 442963 528329 2597837 2834738 X NETWORK ADVERTISING INITIATIVE (NAI) IS A TRADE ASSOCIATION FORMED TO PROVIDE ADVOCACY, EDUCATION AND A FORUM FOR THE DISCUSSION OF PRIVACY AND TECHNOLOGY IN DIGITAL ADVERTISING, AND TO CREATE AND ENFORCE A SELF-REGULATORY CODE OF CONDUCT FOR ADVERTISING TECHNOLOGY COMPANIES. 0 0 IN 2022, THE NAI'S SELF-REGULATORY PROGRAM FOCUSED ON: (1) CROSS-INDUSTRY AND CROSS-TRADE DIALOGS TO HELP DEVELOP A NEW PRIVACY FRAMEWORK AND TECHNICAL STANDARDS FOR DIGITAL ADVERTISING THAT ARE CONSISTENT WITH EMERGING STATE LAWS AND CHANGES IN BROWSERS AND OPERATING SYSTEMS; (2) THE CREATION OF NEW GUIDANCE AND BEST PRACTICES FOR AVOIDING DARK PATTERNS IN NOTICE AND CHOICE FOR DIGITAL ADVERTISING; (3) ANNOUNCEMENT AND IMPLEMENTATION OF NEW GUIDANCE FOR THE COLLECTION AND USE OF PRECISE LOCATION INFORMATION FROM SENSITIVE LOCATIONS; AND (4) FURTHER EXPANSION OF PUBLIC POLICY EFFORTS, ADVOCACY, AND OUTREACH ON A STATE AND FEDERAL LEVEL. IN 2022, THE NAI PARTICIPATED IN SEVERAL CROSS-INDUSTRY AND CROSS-TRADE GROUPS TO HELP CREATE AWARENESS OF NEW STATE PRIVACY LEGAL REQUIREMENTS, AS WELL AS PLANNING FOR THE FUTURE DEPRECATION OF THIRD PARTY COOKIES, AND THE EVOLUTION OF ADDRESSABILITY. THE NAI IS AN ACTIVE PARTICIPANT IN TECHNOLOGY FOCUSED CROSS-INDUSTRY EFFORTS SUCH AS THE IAB TECH LAB PRIVACY AND REARC COMMIT GROUP, TCF STEERING GROUP, W3C, AND GOOGLE PRIVACY SANDBOX, KEEPING NAI MEMBERS APPRISED OF DEVELOPMENTS IN THESE GROUPS WHILE SPEAKING ON BEHALF OF THE MANY SMALL AND MEDIUM SIZED COMPANIES THAT REPRESENT NAI MEMBERSHIP. TO FURTHER BOLSTER COLLABORATION, THE NAI OPENED PARTICIPATION IN ITS OWN WORKING GROUPS TO PUBLISHERS, ADVERTISERS, LAW FIRMS, AND OTHER STAKEHOLDERS IN THE DIGITAL ADVERTISING ECOSYSTEM.IN MAY 2022, THE NAI DEVELOPED AND ANNOUNCED A NEW RESOURCE FOR MEMBER THAT EDUCATES MEMBER COMPANIES THAT INFORMS THEM ABOUT THE PRACTICE OF DARK PATTERNS AND HELPS THEM TO IMPLEMENT BEST PRACTICES TO AVOID USING DARK PATTERNS IN DIGITAL ADVERTISING. NAI LEGAL AND POLICY STAFF DEVELOPED THE REPORT, ENTITLED "BEST PRACTICES FOR USER CHOICE AND TRANSPARENCY." THIS REPORT IDENTIFIED BEST PRACTICES AND GUIDED COMPANIES IN MAXIMIZING EFFECTIVE AND EFFICIENT NOTICE AND CHOICE MECHANISMS WITH RESPECT TO COLLECTING CONSUMER DATA, EXAMINED THE CURRENT LEGAL ENVIRONMENT AT THE STATE AND FEDERAL LEVELS, AND EXPLAINED CONSUMER CHOICE AND TRANSPARENCY OBLIGATIONS UNDER THE NAI CODE OF CONDUCT (CODE).IN JUNE 2022, THE NAI ANNOUNCED THE DEVELOPMENT OF NEW GUIDANCE AROUND THE USE OF PRECISE LOCATION DATA FROM SENSITIVE LOCATIONS. FOUR NAI MEMBER COMPANIES COMMITTED PUBLICLY TO FOLLOW THE GUIDANCE, ENTITLED "NAI ENHANCED STANDARDS FOR PRECISE LOCATION INFORMATION SOLUTION PROVIDERS (ENHANCED STANDARDS)." THE ENHANCED STANDARDS PROHIBIT THE USE, SALE, AND TRANSFER OF PRECISE LOCATION DATA FROM SENSITIVE PLACES, SUCH AS THOSE TIED TO RELIGIOUS WORSHIP, SENSITIVE HEALTHCARE SERVICES, MILITARY BASES, AND THOSE INDICATING LGBTQ+ IDENTITY. THEY ALSO RESTRICT COMPANIES FROM USING, SELLING, OR SHARING, IN THE ABSENCE OF A LEGALLY-BINDING REQUEST, PRECISE LOCATION DATA FOR LAW ENFORCEMENT OR NATIONAL SECURITY PURPOSES. THE NAI ALSO FILED SUBSTANTIAL COMMENTS TO THE FEDERAL TRADE COMMISSION (FTC) IN RESPONSE TO THEIR ADVANCE NOTICE OF PROPOSED RULEMAKING ON COMMERCIAL SURVEILLANCE AND DATA SECURITY. THE NAI'S COMMENTS RECOMMENDED THAT THE FTC INTEGRATE SELF-REGULATION IN THE DIGITAL ADVERTISING INDUSTRY INTO ANY RULES CREATED BY THE AGENCY'S ONGOING REGULATORY PROCESS AROUND PRIVACY. THE NAI BELIEVES THAT THE FTC CAN ENHANCE CONSUMER PRIVACY AND DATA PROTECTION BY PROMOTING SELF-REGULATION, SUCH AS THROUGH THE CODE, IN COLLABORATION WITH FEDERAL REGULATORS. IN ADDITION TO ADVOCATING FOR STRONG SELF-REGULATION, THE NAI'S COMMENTS CALL ON THE FTC TO MAXIMIZE COMPETITION ACROSS THE DIGITAL ADVERTISING ECOSYSTEM BY FOCUSING ON THE HARMFUL USES OF DATA AND THE IMPLEMENTATION OF DATA STEWARDSHIP REQUIREMENTS ACROSS THE ENTIRE INDUSTRY, AND BOLSTER THE ROLE OF TRANSPARENCY AND CONSUMER CONTROL THROUGH CLEAR GUIDANCE, WHILE SEEKING TO ESTABLISH BROAD DATA COLLECTION AND USE RESTRICTIONS.THE NAI CODE INCLUDES PRINCIPLES RELATED TO TRANSPARENCY, CHOICE, DATA MINIMIZATION, PURPOSE AND USE RESTRICTION, DATA SECURITY, AND OTHERS. ALTHOUGH MANY OF NAI'S RESOURCES GO TO ENSURING THAT THE ADVERTISING ECOSYSTEM OPERATES IN A TRANSPARENT MANNER, AND THAT CHOICES PROVIDED TO CONSUMERS WORK AS EXPECTED, TRANSPARENCY AND CHOICE ALONE ARE BY NO MEANS SUFFICIENT TO PROTECT CONSUMERS, AND THE NAI IS ACTIVELY WORKING TO INTRODUCE NEW GUIDANCE AND REQUIREMENTS REGARDING DATA MINIMIZATION AS WELL AS USE RESTRICTIONS FOR VARIOUS DATA TYPES. ONE NEW MEMBER JOINED THE NAI IN 2022. THE NAI'S MEMBERSHIP INCLUDES STARTUP, SMALL TO MEDIUM SIZED BUSINESSES, AND SOME OF THE LARGEST AND MOST IMPORTANT COMPANIES IN THIRD-PARTY DIGITAL ADVERTISING ECOSYSTEM. THE NAI IS ALSO WORKING MORE CLOSELY WITH ADVERTISERS AND PUBLISHERS AS THEY EMBRACE A LARGER ROLE IN THE DIGITAL ADVERTISING ECOSYSTEM, LEVERAGING THEIR OWN DATA TO HELP DELIVER BETTER ADVERTISING IN PRIVACY-PROMOTING WAYS. THE NAI HELD ITS ANNUAL MEMBER SUMMIT IN MAY 2022; THE FIRST IN PERSON EVENT SINCE THE COVID-19 PANDEMIC. THROUGH A SERIES OF VIRTUAL AND IN PERSON EVENTS, NAI PROVIDED ITS MEMBER COMPANIES WITH THE LATEST INFORMATION ON EMERGING TECHNOLOGIES, REGULATORY AND LEGISLATIVE TRENDS, AND EMERGING BUSINESS MODELS, AS WELL AS THE PRIVACY IMPLICATIONS OF THE PANDEMIC. THE NAI COORDINATED SEVERAL WORKING GROUPS TO DISCUSS CODE UPDATES, EMERGING PRIVACY AND TECHNOLOGY ISSUES AND PRIVACY REGULATION AND LEGISLATION, INCLUDING THE USE OF PRECISE LOCATION DATA, INTERNATIONAL LEGISLATIVE AND REGULATORY DEVELOPMENTS, AND REGULATIONS PROMULGATED UNDER THE CALIFORNIA PRIVACY RIGHTS ACT (CPRA). THE NAI COMPLIANCE STAFF PUBLISHED THE 2021 NAI ANNUAL MEMBER COMPLIANCE REPORT AND INITIATED THE REVIEW PROCESS FOR THE 2022 REPORT. THE NAI ALSO HOSTED A VARIETY OF ROUNDTABLE DISCUSSIONS AND MEMBER BRIEFINGS ON VARIOUS CONSUMER PRIVACY INITIATIVES, GLOBAL LEGISLATIVE AND REGULATORY UPDATES, AND INDUSTRY TRADE ASSOCIATION ACTIVITIES. THE NAI SERVED ON THE GOVERNING BOARD AND STEERING COMMITTEE OF THE IAB EUROPE'S TRANSPARENCY & CONSENT FRAMEWORK (TCF), AN INDUSTRY TOOL THAT SUPPORTS COMPANIES WITHIN THE DIGITAL ADVERTISING ECOSYSTEM AS THEY MANAGE THEIR COMPLIANCE OBLIGATIONS WITH THE EU'S GENERAL DATA PROTECTION REGULATION (GDPR) AND EPRIVACY DIRECTIVE, ON THE BOARD OF PRIVACY FOR AMERICA, AND ON THE BOARD OF THE PARTNERSHIP FOR RESPONSIBLE MEDIA (PRAM). 0 0 0 1 0 0 0 0 0 1 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1 8 1 0 0 0 0 0 0 0 0 X 12 12 0 0 0 0 1 1 1 1 1 0 0 0 0 0 0 1 0 0 X LEIGH FREUND 5713660500 409 7TH STREET NW 250 WASHINGTON DC 20004 KAREN MILLER REESE VICE PRESIDENT & CHIEF PRIVACY OFFICER 5.00 X X 0 0 0 ALAN CHAPELL PRESIDENT 5.00 X X 0 0 0 DANA EDWARDS GENERAL COUNSEL 5.00 X X 0 0 0 KEN DREIFACH CSHAREHOLDER 5.00 X X 0 0 0 GHITA HARRIS-NEWTON DIRECTOR, PUBLIC AFFAIRS 5.00 X 0 0 0 DUNCAN MCCALL CEO 5.00 X 0 0 0 PAUL HARRISON CTO 5.00 X 0 0 0 TAMERA REYNOLDS SENIOR PARTNER 5.00 X 0 0 0 GUINEVERE JOBSON GENERAL COUNSEL 5.00 X 0 0 0 RACHEL GLASSER CHIEF PRIVACY OFFICER 5.00 X 0 0 0 BROOKS DOBBS DATA PRIVACY GENERAL MANAGER 5.00 X 0 0 0 ALEXIA TOMAZOS HEAD OF LEGAL & BUSINESS AFFAIRS 5.00 X 0 0 0 LEIGH FREUND PRESIDENT & CEO 40.00 X 470102 0 0 DAVID LEDUC VICE PRESIDENT, PUBLIC POLICY 40.00 X 309894 0 0 ANTHONY MATYJASZEWSKI VICE PRESIDENT, COMPLIANCE 40.00 X 244716 0 0 FARAH ZAMAN GENERAL COUNSEL 40.00 X 305827 0 0 RYAN SMITH COUNSEL 40.00 X 143000 0 0 1473539 0 0 5 0 1 0 RATIONAL 360 1828 L ST NW WASHINGTON DC 20036 PR & MARKETING 171197 1 MEMBERSHIP DUES 900099 3707886 3707886 DAA REVENUE 900099 108400 108400 NAI SUMMIT 900099 57388 57388 3873674 3873674 3873674 0 0 470102 1297291 36838 163885 89712 111043 55041 39356 167358 28061 156007 135334 197092 747 52826 DAA EXPENSES 472290 INDUSTRY PUBLIC POLICY 130000 DUES AND SUBSCRIPTIONS 19260 COLLECTIONS 10763 3767 3636773 2808895 3130594 198443 178500 19492 40750 12105 11982 870 123 13100 13100 3040800 3363067 408708 505394 34255 22935 442963 528329 X 2497837 2608738 100000 226000 2597837 2834738 3040800 3363067 236901 0 X 0 0 0 0 0 1 3707886 440000 -43073 396927 556183 -159256 10878 10878 0 1227 1104 123 123 DEFERRED RENT 22935 22935 X X 0 0 0 LEIGH FREUND PRESIDENT & CEO 352292 0 117810 0 0 0 0 0 0 0 470102 0 0 0 DAVID LEDUC VICE PRESIDENT, PUBLIC POLICY 269473 0 40421 0 0 0 0 0 0 0 309894 0 0 0 FARAH ZAMAN GENERAL COUNSEL 263077 0 42750 0 0 0 0 0 0 0 305827 0 0 0 ANTHONY MATYJASZEWSKI VICE PRESIDENT, COMPLIANCE 212797 0 31919 0 0 0 0 0 0 0 244716 0 0 0 FORM 990, PART VI, SECTION A, LINE 6 THE ORGANIZATION HAS ONE CLASS OF MEMBERSHIP. FORM 990, PART VI, SECTION A, LINE 7A NETWORK ADVERTISING INITIATIVE MEMBERS VOTE FOR AT-LARGE BOARD MEMBERS. FORM 990, PART VI, SECTION A, LINE 7B CERTAIN CHANGES TO THE NETWORK ADVERTISING INITIATIVE CODE OF CONDUCT ARE APPROVED BY FULL MEMBERSHIP. FORM 990, PART VI, SECTION B, LINE 11B THE PRESIDENT & CEO REVIEWED THE FORM 990 BEFORE IT WAS FILED WITH THE IRS. FORM 990, PART VI, SECTION B, LINE 15A AN EXECUTIVE COMMITTEE PREPARES A BUDGET FOR THE COMPENSATION OF THE PRESIDENT AND CEO, AND THE BOARD OF DIRECTORS APPROVES THIS BUDGET. THE PRESIDENT AND CEO SETS A BUDGET FOR STAFF COMPENSATION, WHICH IS THEN REVIEWED AND APPROVED BY THE BOARD OF DIRECTORS. THE LAST REVIEW TOOK PLACE IN NOVEMBER 2022. FORM 990, PART VI, SECTION C, LINE 19 THE NETWORK ADVERTISING INITIATIVE MAKES DOCUMENTS AVAILABLE UPON REQUEST.