The TCF 2.x provides exact guidelines on how the CMP should be graphically designed and which content must be presented to the user at which user levels. However, with areas such as colour, fonts, background and the placement of the company’s logo, there will continue to be scope for creativity to a certain extent. Thus, customisation to the company’s CI will still be possible. Furthermore, you can continue to label the individual layers yourself and add further texts to the banner and privacy policy. The texts displayed on the buttons can also be freely selected (e.g. the Reject/Accept buttons).
Find all the answers to your TCF questions here:
How can I tell if I have TCF enabled?
Can I display a Privacy Wall instead of the banner?
Can I continue to work with non-IAB vendors?
Can I incorporate non-IAB vendors into the CMP?
Can I simply incorporate the entire Global Vendor List for TCF?
Can I amend the text of the Data Processing Services (DPS)?
Does the TCF require a "reject" button in the first layer of the banner?
Do I have to offer the user granular selection options on the first banner layer with TCF?
As a publisher, can I define the legal basis for my own (data processing) purposes?
Does TCF forbid "continuing to scroll" as consent?
How can I tell if I have TCF enabled?
There are subtle differences between a standard banner with- and without TCF enabled. The most noticeable would be that the TCF banner does include Purposes, Features, and Vendors. In the first layer information is provided about Purposes and Features. On the second layer of the CMP users can enable and disable each Purpose and Vendor separately.
If you are unsure whether or not you are using the Usercentrics CMP with the TCF framework enabled, please check your setup of the CMP Configuration/Setting-ID:
Go to your Service Settings and check whether you see a Global Vendor List tab. If you do, TCF is activated in that Configuration.
Can I display a Privacy Wall instead of the banner?
The guidelines of the TCF, according to the current situation, provide for asking for personal privacy settings via a centrally placed Privacy Wall.
Can I continue to work with non-IAB vendors?
Yes. Publishers will also still be able to work with vendors who have not committed themselves to TCF. However, TCF 2.0 stipulates that it must be clear for the user whether the vendor is from the IAB’s Global Vendor List or if it is a non-IAB vendor. For this reason, the framework recommends clearly listing both groups separately.
Can I incorporate non-IAB vendors into the CMP?
This is possible. You can add these services to your configuration as before in the Usercentrics Admin Interface via the menu option “Service Settings”.
Can I simply incorporate the entire Global Vendor List for TCF?
You can add these services to your configuration in our Admin Interface via the menu option “Service Settings”. However - for reasons of transparency and user friendliness - it is recommended that you do not incorporate the entire list but limit yourself to third party providers to whom data will actually be forwarded for processing.
Can I amend the text of the Data Processing Services (DPS)?
No. The information about vendors who are registered on the Global Vendor List (GLV) is comprehensively laid down by the IAB and can be amended neither by Usercentrics nor our customers. These texts are automatically entered into the Usercentrics database, updated weekly and publishers can then incorporate them into their CMP.
Information regarding non-IAB vendors can be generated as before from our own service database and it also remains possible to generate custom DPS here. These providers/services will retain the current lock logic through our CMP.
Does the TCF require a “Reject” button in the first layer of the banner?
No. According to TCF 2.0 guidelines the first layer must contain only an action request for the user such that he or she can provide consent (e.g. “Accept”, “OK”, “Allow” etc.) and provide an option to amend the selection (e.g. “advanced settings”, “customise selection” etc.). TCF 2.0 guidelines do not require an action request in the first layer which enables the user to revoke consent. It is up to the publisher whether or not to show a “Reject” button in the first layer if you wish to do so or if local laws require it.
For your information: The setting which shows a “Reject” button in the first layer is activated by default in the Usercentrics CMP although this option can also be deactivated. Important to know: If the user is not given the option to opt out in the first layer, the website may no longer be GDPR compliant. Seek the advice of your lawyer or legal department before taking this step.
Do I have to offer the user granular selection options on the first banner layer with TCF?
As a publisher can I define the legal basis or purposes for individual vendors?
TCF 2.0 offers publishers the option to define which legal bases and for what purpose your users’ personal data can be processed by the respective vendor. Publishers can thereby define customer requirements in accordance with their own commercial and legal considerations, e.g. the exclusive use of explicit consent as a legal basis or, for example, only allow certain processing purposes with selected providers.
As a publisher can I define the legal basis for my own (data processing) purposes?
Yes. The guidelines of TCF 2.0 allow publishers to administer and save their own legal bases in their CMP for a variety of data processing purposes. This also applies explicitly for processing purposes which are not supported by the framework. This information can be found in the “Publisher TC Segment” of the TC string which serves to ensure seamless transfer of the publishers’ legal bases to the vendors with whom they work.
Does TCF forbid "continuing to scroll" as consent?
No. No exact definition or guideline can be found in the guidelines of TCF detailing how user consent (e.g. explicit or implicit) is to be obtained. By implication, publishers therefore have the option to regard “continuing to scroll” as user consent.