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The policy discloses that third-party advertising companies place cookies on user devices for targeted advertising across ADP and other websites, while stating these companies do not collect personal data in this process. The policy also states that ADP websites do not recognize browser Do Not Track signals.
This analysis describes what ADP's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The disclosure that ADP websites do not recognize Do Not Track signals may engage applicable state privacy requirements, including California's requirement under the California Online Privacy Protection Act (CalOPPA) to disclose how a site responds to Do Not Track signals. The policy provides an opt-out mechanism via the NAI and a third-party opt-out URL.
Interpretive note: Whether ADP's third-party advertising cookie data flows constitute a sale or sharing of personal information under CCPA/CPRA is not resolved by the policy's assertion that no personal data is provided to advertising companies, and depends on legal analysis of the specific data flows.
ADP deleted the cookie preference management tool that previously allowed users to understand and control which cookies were placed on their devices, including functional, analytics, and advertising cookies. The removal eliminates the transparency mechanism through which users could consent to or opt out of different cookie categories. The practical effect depends on whether ADP has replaced this functionality elsewhere or whether cookies continue to be placed without equivalent granular user control.
View change record →Under this clause, third-party advertising companies may place tracking cookies on user devices when visiting ADP websites, and ADP websites do not process browser Do Not Track signals. Individuals can opt out of targeted advertising from many third-party advertising companies at http://bit.ly/2Ig9IgT or through the Network Advertising Initiative at www.networkadvertising.org.
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"ADP has relationships with Third Party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These Third Party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These Third Party advertising companies do not collect Personal Data in this process, and we do not give Personal Data to them as part of this process. Although our websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer Individuals choices to manage their preferences that are provided in the previous sections above.Excerpt from ADP's Privacy Statement
REGULATORY LANDSCAPE: The Do Not Track non-recognition disclosure engages CalOPPA, which requires California-facing websites to disclose their response to Do Not Track signals. The policy satisfies this disclosure requirement by stating the website does not currently recognize such signals. Third-party cookie-based advertising may also engage CCPA/CPRA provisions regarding the sale or sharing of personal information with third parties for cross-context behavioral advertising, depending on the classification of the data flows involved. The FTC and California Privacy Protection Agency are the relevant enforcement authorities. GOVERNANCE EXPOSURE: Medium. The policy asserts that third-party advertising companies do not collect personal data through this process and that ADP does not provide personal data to them; however, whether the cookie-based data flows constitute a 'sale' or 'sharing' under CCPA/CPRA — which can include non-monetary transfers of personal information to third parties for advertising purposes — depends on a legal analysis not resolved by this document's assertion alone. JURISDICTION FLAGS: California creates the highest exposure, as CPRA's definition of 'sharing' personal information for cross-context behavioral advertising does not require monetary consideration. EU and EEA jurisdictions require consent for non-essential cookies under the ePrivacy Directive and applicable national implementing laws. The adequacy of ADP's cookie consent mechanism for EU visitors should be assessed. CONTRACT AND VENDOR IMPLICATIONS: Organizations whose employees or contacts use ADP web properties should be aware that third-party advertising cookies may be placed by entities outside ADP's direct contractual relationship with those users. Review of ADP's cookie consent and opt-out mechanisms may be appropriate for organizations subject to GDPR or CCPA. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether ADP's third-party advertising data flows constitute a 'sale' or 'sharing' under CCPA/CPRA and, if so, whether the opt-out mechanisms provided satisfy CPRA's opt-out of sale and sharing requirements. EU compliance teams should confirm whether ADP's cookie consent banner satisfies applicable ePrivacy requirements for the relevant jurisdiction.
The disclosure that ADP websites do not recognize Do Not Track signals may engage applicable state privacy requirements, including California's requirement under the California Online Privacy Protection Act (CalOPPA) to disclose how a site responds to Do Not Track signals. The policy provides an opt-out mechanism via the NAI and a third-party opt-out URL.
Under this clause, third-party advertising companies may place tracking cookies on user devices when visiting ADP websites, and ADP websites do not process browser Do Not Track signals. Individuals can opt out of targeted advertising from many third-party advertising companies at http://bit.ly/2Ig9IgT or through the Network Advertising Initiative at www.networkadvertising.org.
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