NFL Voluntarily Complies with BBB National Programs’ Digital Privacy Watchdog Consumer Data Privacy Standards

NFL’s Collaboration with Digital Advertising Accountability Program Highlights Vital Role of Industry Self-Regulation Amid Shifting Regulatory Environment

McLean, VA – February 27, 2025 – The National Football League (NFL) has collaborated with BBB National Programs’ Digital Advertising Accountability Program (DAAP) to enhance its privacy disclosures to follow the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising (OBA).

The NFL, comprising 32 teams and attracting a vast consumer audience, averaging 17.5 million viewers per game in 2024 and over 120 million for this year’s Super Bowl, plays a significant role in the digital advertising landscape.

DAA’s Self-Regulatory Principles for OBA apply to entities engaged in interest-based advertising (IBA) to help ensure they adhere to consumer data privacy best practices. The OBA Principles were developed by leading industry associations to apply consumer-friendly standards to online behavioral advertising across the internet.

“Ensuring that organizations such as the NFL adhere to the DAA Principles is crucial for maintaining consumer trust in the digital advertising ecosystem,” said Mary K. Engle, EVP, Policy, BBB National Programs. “By implementing these best practices, the NFL now not only complies with industry standards but also demonstrates a commitment to protecting consumer privacy.”

According to DAAP, enhanced notice links with clear opt-outs, and, in the case of sensitive data such as precise location data, opt-in consent mechanisms, ensure consumers are fully informed about data collection practices and can make educated decisions about their privacy.

DAAP reviewed NFL-affiliated websites and mobile apps and found instances where disclosures were not made in the manner contemplated by the DAA’s OBA Principles and Mobile Guidance. While DAAP’s review found that the NFL’s privacy policy contained most of the requirements in the DAA Principles, DAAP recommended, and the NFL agreed, to revise disclosures to provide “enhanced notice” in the manner contemplated by the DAA Principles.

Key issues identified by DAAP include:

• Enhanced Notice for Website Data Collection: The investigation found that the 32 NFL team websites lacked the enhanced notice for data collection by third-party companies contemplated under the OBA Principles.
• Mobile Data Collection: Some of the apps collected precise location data without fully disclosing in the manner contemplated by DAA’s Mobile Guidance how such data could be shared with third parties for advertising. The DAA Principles require clear notice and opt-in consent for the sharing of such sensitive data for IBA.

In response to DAAP’s inquiry, the NFL conducted comprehensive reviews of the areas identified for improvement. The NFL collaborated with DAAP on the following:

• Updated Privacy Policies: Updated the NFL global privacy policy and team privacy policies to provide additional information about IBA and possible use of consumers’ precise geolocation data for advertising/IBA.
• Enhanced Notice Links: Added enhanced notice links on websites and apps, directing users to IBA-related information.
• Clear Consent Mechanisms and Disclosures: Implemented clearer and more prominent consent prompts – through the creation of new splash screens that provide strengthened notice and a clickable link to the IBA section of the privacy policy – for precise geolocation data collection on mobile apps.
• Enhanced Notice of Use of Precise Geolocation Data: Certain NFL team apps now display a splash screen stating that precise geolocation data may be shared with third-party advertisers for IBA. Users can learn more via a link to the Privacy Policy.
• Opt-In Consent Requirements for Sensitive Data/Precise Geolocation Consent Prompts: NFL updated certain team apps to provide clearer notice and obtain user consent for collecting precise geolocation data for IBA. This includes a notice on the splash screen and a consent prompt when users click “Continue.”
• Enhanced Notice for Third-Party IBA – Mobile App Store Profile and Account Settings: Certain NFL team apps added enhanced notice links for precise location data at the point of collection and in in-app settings. The NFL’s global and team apps’ privacy policies now include a link to IBA-related information, which can be accessed through the “Privacy Policy” link in the app store. Additionally, certain NFL teams have updated their app settings pages to include an enhanced notice link (usually titled “Ad Choices”), which directs users to the IBA portion of the team’s privacy policy.

“In an evolving legislative and regulatory climate, industry self-regulation is crucial for protecting consumer privacy and digital advertising rights, ensuring transparency and accountability in the marketplace,” said Dr. Divya Sridhar, Vice President, Global Privacy Division and Privacy Initiatives Operations, BBB National Programs. “The changes the NFL has made to its apps and websites set an important precedent for other organizations within the digital ads ecosystem.”

The NFL stated, “At the National Football League (NFL), we are committed to providing a seamless user experience for our fans, as well as safeguarding their information. We are grateful for the opportunity to participate in the Digital Advertising Accountability Program and appreciate their acknowledgement that we are compliant with the DAA Principles.”

A DAAP decision does not constitute a finding that the law has been violated, nor should the NFL’s modification of its IBA practices, in cooperation with DAAP’s self-regulatory processes, be construed as an admission of a violation of law.

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.