The “Transparency and Consent Framework (TCF)” of the International Advertising Bureau Europe (IAB)* is a technical standard spanning multiple sectors for the retrieval and transfer of a user’s consent signals between publishers and third party providers who have committed themselves to the framework (e.g. Google, Criteo, Quantcast or Taboola). The framework thereby establishes a “common language” on whose basis all participants in the advertising value chain can communicate, and which enables marketing to be conducted legally in the future via these channels.
The TCF is primarily relevant for publishers whose core business lies in monetising their own content through advertising - and who work together with third party providers.
*What is IAB?
The Interactive Advertising Bureau Europe (IAB Europe) is an international business organisation for the online advertising sector. In its own words, the organisation represents the interests of companies from the digital advertising and media industry, ensures consistency and standardisation and serves to improve the use of digital advertising channels for advertising customers.
All vendors who have committed themselves to TCF 2.2 can be found on the Global Vendor List (GLV) which is updated weekly by the IAB.
TCF version 2.2
General changes:
- Legitimate interest can no longer be selected as a legal basis for advertising and content personalization (purposes 3, 4, 5 and 6). We will remove the option to select legitimate interest for these purposes. For purposes 3, 4, 5 and 6, you as a publisher must obtain consent for the vendors to process the data.
- A new purpose, purpose 11, will be added. This purpose is: "Use limited data to select content". This purpose is included in stack 43: "Content can be selected based on limited data. Content performance can be measured". More information on purpose 11 and stack 43 can be found in the IAB Europe TCF Policies.
The Usercentrics CMP can display this purpose and enable you to use limited data to select content if the vendors choose this specific purpose. We provide flexibility to choose the legal basis: consent or legitimate interest.
- There will be a new Global Vendor List, GVL v3. When you migrate to TCF v2.2, you will automatically migrate to the GVL 3 too.
User Interface Changes:
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The Usercentrics CMP will display the total number of vendors (IAB and non-IAB vendors) in the text on the first layer.
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New information added by the vendors will be disclosed to the end users. On the second layer, we will add the following information:
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Categories of data collected
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Retention periods on a per purpose basis
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Link to more information on legitimate interest(s) - where applicable
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An opt-in and opt-out option need to be provided on all CMPs. Usercentrics CMP already provides options to add it to the First and Second Layer and you can choose which implementation you prefer.
Does the TCF demand that user consent be obtained every time the Global Vendor List is changed?
Every time the user is shown the privacy banner e.g. on the first visit to the website or when the user wishes to change his or her personal privacy settings, the TCF 2.0 requires that this occurs based on the newest version of the Global Vendor List (GLV).The TCF 2.2 guidelines do not, however, require that users check and update their selection every time the GVL is updated.
The user’s TC strings may, however, not be updated without the user interface being presented once again and the privacy settings preferences queried. It lies at the discretion of the CMP and/or the publisher to decide whether changes in the GVL compared to a previous version used to confirm the user’s privacy settings justify the banner being shown again. The TCF 2.2 guidelines merely require that users are reminded every 13 months at the latest of their right to revoke their consent and/or to object to the processing of their data.
What is the difference between Global Scope and Service Specific Scope?
TCF gives publishers two options for how you may wish to share your consent information:
Global Scope: If the user makes a consent decision on a website, this will be stored as part of the framework and all other websites working with a CMP activated for TCF 2.0 and who operate in Global Scope have the ability to access this consent information. Important to know: If the user sets his or her privacy settings in Global Scope, these settings shall be binding for all parties participating in Global Scope. Important: This also applies for cases in which the user does NOT grant consent. For example, if a user makes the decision not to provide consent on another website, all other websites from the group must likewise respect this decision.
Important
The following fundamental question must be clarified with Global Scope: Is it clear to the user (even if he or she has been informed accordingly in the banner text) with whom the information is shared? The framework itself offers this option but does not make any point as to how this approach should be legally evaluated. Publishers should definitely consult their lawyers or legal departments on this point.
Service Specific Scope: Only privacy settings relating to the website for which they were requested are valid here.
Important
Google has announced that it will only support TCF 2.0 in the Service Specific Scope. Further information can be found here.
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