DTSG UK Good Practice Principles
2. Compliance and Enforcement
Following a commitment to the Principles, each Signatory will have their ad misplacement minimisation policies independently verified by a JICWEBS*-approved provider ("Verification Provider") within six months and thereafter every year.
This paper, accompanying the Principles, sets out how this process will work and the requirements for (i) selecting a Verification Provider and (ii) the review of a Signatory's policies by a Verification Provider. The DTSG may evolve the detail and depth required from independent verification, as the Principles themselves evolve, and according to the DTSG Terms of Reference.
2.1 Selection of Verification Provider
A Signatory must choose and use a Verification Provider** that is a registered auditor and member of either The Institute of Chartered Accountants in England and Wales (ICAEW), The Institute of Chartered Accountants of Scotland (ICAS), The Institute of Chartered Accountants in Ireland (ICAI) or The Association of Chartered Certified Accountants (ACCA). In exceptional circumstances a Signatory may apply to JICWEBS to use a provider who is not a member of one of the above bodies, setting out the exceptional circumstances for consideration.
These exceptional circumstances will be in addition to the following criteria:
Be independent of and / or not owned by any Signatory, DTSG business or relevant individual Trade Association; and
- Maintain business operations in the UK.
JICWEBS will consider the application of Verification Providers in a timely manner and will not unreasonably withhold its approval thereof. All providers will be subject to annual review by JICWEBS and will submit compliance certificates and copies of relevant supporting material to JICWEBS, which will act as a central depository for this process.
JICWEBS will publicly disclose all its certification requirements and its review decisions regarding Verification Providers submitted for approval.
2.2 Independent Policy Verification Process
The Verification Provider will check the Signatory's compliance with the Principles. The Signatory must provide the Verification Provider with relevant information regarding the ad misplacement policies in force, and supplement such information by email or telephone correspondence as required.
Relevant written information may include:
Contract terms and policies relating to the transactions of ads;
A statement of reasonable endeavours applied to minimise the risk of ad misplacement,
Internal policies, procedures and controls relating to the placement of ads, such as the:
details regarding the use of CV tools and appropriate / inappropriate schedules;
names and training of personnel with enforcement responsibility; and
The Verification Provider must provide the Signatory with a written report of its findings and, if it determines that the Signatory's policies are compliant with the Principles, a Verification Submission form should be sent to JICWEBS to consider if a certificate and seal will be issued.
Please note: Independent Verification is limited solely to whether the Signatory has implemented policies for minimising ad misplacement in compliance with the Principles. It does not extend to testing the effectiveness of any processes, procedures or controls for ad misplacement. The compliance certificate issued by the Verification Provider only covers the Signatory's policies for minimising ad misplacement.
* JICWEBS is the UK's Joint Industry Committee for Web Standards and is made up of the following trade bodies: Association of Online Publishers (AOP), Internet Advertising Bureau (IAB), Newspaper Society, Newspapers Publishers Association, ISBA – the voice of advertisers and the Institute of Practitioners in Advertising (IPA).
** This will include ABC.
2.3.1 Verification submission
A standard verification form, available from JICWEBS, should be completed and jointly submitted by the Signatory and Verification Provider to JICWEBS.
Against each principle this form should include a description of how the signatory has complied with the principle during the period of review. This should include sufficient information, from documented policies and processes, so that the reader can have a clear understanding of the policy and processes . As a minimum this must be in the form of a summary and/or extracts from relevant documents. In addition links to the relevant documents/sections can be incorporated into the submission.
Information not relevant to the DTSG GPP scheme should not be included in the submission. For example anti-fraud processes are outside the scope of the scheme.
The information on the verification submission will be replicated on the certificate.
2.3.2 Certificates and Seals
Certificates and seals will be issued by JICWEBS and published on www.jicwebs.org
The seal is comprised of:
JICWEBS DTSG Brand Safety logo
Logo of verification provider (optional)
Month and year that seal is valid to.
The certificate is comprised of:
Signatory’s name and address,
Signatory’s logo (optional)
Month of verification
Compliance findings against the GPPs (as reported on the verification submission)
Verification Provider’s name and address
Statement of the Verification Provider
2.4.1 First seal
A signatory should have their first seal issued within six months of being registered. For example, registration accepted in May 2015 - the first seal should be issued by JICWEBS by end of November 2015.
2.4.2 Subsequent seals
The subsequent seal must be issued before the end of the ‘valid to’ month and year on the current seal.
If a subsequent submission is made early then the new seal can be valid to 12 months from the current seal date, provided that the month of verification is within the timeframe set out in 2.4.4. For example - current seal valid to July 2015, verification work is done in March 2015, submission is made in April 2015 – then new seal would be valid to July 2016.
2.4.3 Verification submission
A joint submission by the Signatory and Verification Provider must be made to JICWEBS in consideration of a seal being issued. This should be at least two weeks before the end of the month in which the seal is to be issued.
If it is likely that the submission will not be made in time then the signatory should formally request JICWEBS to consider a later submission date. The signatory should explain the reason for the delay and suggest a revised submission date. JICWEBS will then inform the signatory of its decision.
2.4.4 Verification work
The month in which the verification work is completed should be no earlier than four months before the month in which the seal is issued. E.g. the verification work is completed in March 2015 then the seal must be issued no later than July 2015.
2.4.5 Signatory listing
JICWEBS will maintain a list of signatories to the JICWEB DTSG GPPs. To be listed, a company must be currently registered with JICWEBS. In addition companies must have a current seal or be within the 6 month period before their first seal is to be issued.
Companies who have been granted a delayed submission date will be de-listed once the required seal issue date has passed. They will be re-listed once a current seal is issued by JICWEBS. The new seal will be valid for 12 months from the original seal issue date (not from the delayed submission date).