TCF (Transparency and Consent Framework) defines four categories for disclosing vendor processing: Purposes, Special Purposes, Features, and Special Features. Each has different rules for legal basis and user rights, and in this table we outline the implications of each based on the TCF Policy.
Purposes
Purposes are the primary processing activities that require user disclosure. TCF defines 11 Purposes.
Consent only
Purposes 1, 3, 4, 5, and 6.
Since TCF 2.2 it has not been permitted to use Legitimate Interest for Purposes 3, 4, 5 and 6.
Consent or Legitimate Interest
Purposes 2, 7, 8, 9, 10, and 11. Vendors can declare either or both. When a user rejects consent, vendors relying on Legitimate Interest can still process under that basis unless the user actively objects.
Legitimate Interest when users Deny consent
Under Legal Specifications in the Usercentrics admin, the option "Apply TCF Legitimate Interest when users don't give consent" controls Legitimate Interest signalling for a reject-all scenario. When enabled, vendors receive a Legitimate Interest signal for Purposes 2, 7, 8, 9, 10, and 11 even when consent is rejected. When disabled, a reject-all removes both the consent and Legitimate Interest signals for these purposes.
Publisher Restrictions
Under the Global Vendor List in the Usercentrics Admin, it is possible to control Publisher Restrictions. In the case that a vendor declared a purpose with a default legal basis (consent or legitimate interest) but also declared this purpose as flexible, the legal basis restriction must be respected if set in the Admin Interface. That means for example if a vendor declared a purpose as legitimate interest but also declared that purpose to be flexible and the legal basis was restricted to consent, the vendor must check for the consent signal and must not apply the legitimate interest signal.In case you want to disable the use of legitimate interest for TCF Purposes for your TCF CMP, you need to restrict all purposes to consent in the Admin Interface.
Special Purposes
Special Purposes operate exclusively under legitimate interest. TCF does not permit users to object to Special Purposes. This applies regardless of user choices on regular Purposes or Vendors, the Usercentrics Legitimate Interest setting or Publisher Restrictions.
If a vendor only declares Special Purposes (and no regular Purposes) under legitimate interest, the CMP must maintain a Legitimate Interest signal for that vendor. The only way to restrict Special Purposes entirely is to not work with vendors that declare Special Purposes.
The three Special Purposes are:
- SP1: Ensure security, prevent and detect fraud, and fix errors
- SP2: Deliver and present advertising and content. Certain information (such as IP address or device capabilities) is used to ensure technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to the user's device.
- SP3: Save and communicate privacy choices (the TC string)
Features
Features describe processing techniques that vendors can apply when they already have a valid legal basis through a declared Purpose. Features do not establish a legal basis on their own, and therefore Features have no toggles in the CMP. They are disclosed for transparency, not for user consent or objection.
The three Features are:
- F1: Match and combine data from other data sources
- F2: Link different devices
- F3: Identify devices based on information transmitted automatically
Special Features
Special Features require explicit user opt-in. Legitimate interest is not permitted for Special Features.
In the latest version of the Usercentrics Admin, it is possible to set the use of Special Features to “Not Allowed”.
The two Special Features are:
- SF1: Use precise geolocation data
- SF2: Identify devices based on information actively requested (Renamed from: Actively scan device characteristics for identification)
Reference table
Purposes
| # | Name | Consent | Legitimate Interest | Right to Object | Note |
|---|---|---|---|---|---|
| 1 | Store and/or access information on a device | Yes | No | N/A | |
| 2 | Use limited data to select advertising | Yes | Yes | Yes | |
| 3 | Create profiles for personalised advertising | Yes | No | N/A | |
| 4 | Use profiles to select personalised advertising | Yes | No | N/A | |
| 5 | Create profiles to personalise content | Yes | No | N/A | |
| 6 | Use profiles to select personalised content | Yes | No | N/A | |
| 7 | Measure advertising performance | Yes | Yes | Yes | |
| 8 | Measure content performance | Yes | Yes | Yes | |
| 9 | Understand audiences through statistics or combinations of data from different sources | Yes | Yes | Yes | |
| 10 | Develop and improve services | Yes | Yes | Yes | |
| 11 | Use limited data to select content | Yes | Yes | Yes |
Special Purposes
| # | Name | Consent | Legitimate Interest | Right to Object | Note |
|---|---|---|---|---|---|
| SP1 | Ensure security, prevent and detect fraud, and fix errors | No | Yes | No | TCF does not allow Special Purposes to be objected to |
| SP2 | Deliver and present advertising and content | No | Yes | No | TCF does not allow Special Purposes to be objected to |
| SP3 | Save and communicate privacy choices | No | Yes | No | TCF does not allow Special Purposes to be objected to |
Features
| # | Name | Consent | Legitimate Interest | Right to Object | Note |
|---|---|---|---|---|---|
| F1 | Match and combine data from other data sources | N/A | N/A | N/A | Features do not establish a legal basis. They can only be used in conjunction with an established legal basis for another purpose. |
| F2 | Link different devices | N/A | N/A | N/A | Features do not establish a legal basis. They can only be used in conjunction with an established legal basis for another purpose. |
| F3 | Identify devices based on information transmitted automatically | N/A | N/A | N/A | Features do not establish a legal basis. They can only be used in conjunction with an established legal basis for another purpose. |
Special Features
| # | Name | Consent | Legitimate Interest | Right to Object | Note |
|---|---|---|---|---|---|
| SF1 | Use precise geolocation data | Yes | No | N/A | Special Features only allowed processing based on consent. |
| SF2 | Identify devices based on information actively requested | Yes | No | N/A | Special Features only allowed processing based on consent. Renamed in TCF Policy but not yet in TCF Specification |
TCF Policy is available here: https://iabeurope.eu/iab-europe-transparency-consent-framework-policies/