IAB Europe Press Release: Global Network of IABs holds annual meetings as industry GDPR compliance standard reaches new milestones

Brussels, London, 8 November 2018— The global community of national IABs, the digital advertising industry’s leading industry association network, kicks off two days of meetings in London today.

The European organisations, 25 national IABs in all, will be joined by 32 sister organisations from North America, Latam and Asia for the IAB Global Summit over 8thand 9thNovember.  IAB UK and IAB Europe are co-hosting the Global Summit.

“It is an honour for us to host the first IAB Global Summit to be held outside of the US”, said Jon Mew, CEO of IAB UK.

“The Summit is an opportunity every year for this growing, vibrant international network to reconnect, reflect and re-energise,” noted Randall Rothenberg, CEO of IAB. “The network’s international reach is a unique asset for member companies in all markets, enabling us to spot trends and drive change in a way that no purely national organisation can, and mapping to the global nature of the industry.”

The meetings coincide with important progress in the rollout of the IAB Europe Transparency & Consent Framework (Framework), a global standard created to help companies in the industry comply with key provisions of the EU’s General Data Protection Regulation (GDPR). The GDPR was adopted in 2016 and has been in force since 25th May 2018.

The Framework is showing strong market uptake, with over 450 third party ad tech companies and agencies registered on its Global Vendor List (GVL) and the roster of registered Consent Management Providers (CMPs) now over 180.  The spike in CMP registrations reflects increasing engagement of the publisher community in the Framework.  IAB Europe is continuing to drive this engagement through increasing investment in the development of the Framework. Supporting this IAB Europe is pleased to announce the appointment of Patrick Verdon as Technical Director IAB Europe, Verdon will work closely with our stakeholders and the policy team at IAB Europe to support the technical development of the Framework. Verdon joins the team from the CMP Databoxer where he was co-founder and CTO.

A key upcoming milestone that Verdon will be working closely on is the publication of revised data processing purposes, which should be available in the coming month. Verdon will be leading the technical aspects of the transitional arrangements as they relate to the GVL and supporting the CMP community.  The purposes are being adapted to reflect feedback received from European Data Protection Authorities (DPAs) and simplify terms and definitions to improve user understanding.

“Many companies are turning to data protection authorities (DPAs) in their markets for guidance on how to interpret vaguely-worded provisions in the in the GDPR, and are struck by the DPAs’ support for, and patience with, industry’s attempts to comply”, noted Townsend Feehan, IAB Europe CEO.  “But we need to bear in mind that though the goodwill is a positive sign, at a certain point the rubber hits the road, and those authorities are going to need to start enforcing the law by investigating and correcting, and imposing penalties for non-compliance. The Framework is fast becoming the industry standard for publishers, app developers and other online services for ensuring that personal data is processed transparently and lawfully under the GDPR, in a way that aligns fully to users’ choices and expectations, while maintaining a healthy ad revenue stream and controlling what their technology partners can and can’t do on their sites and apps.”

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About IAB Europe

IAB Europe is the leading European-level industry association for the online advertising ecosystem. Its mission is to promote the development of this innovative sector and ensure its sustainability by shaping the regulatory environment, demonstrating the value digital advertising brings to Europe’s economy, to consumers and to the market, and developing and facilitating the update of harmonised business practices that take account of changing user expectations and enable digital brand advertising to scale in Europe.

Blog Series: What you always wanted to know about the Transparency & Consent Framework (TCF) / Part 3

On September 25th, we held a 2.5-hour long webinar providing a Complete Overview of the IAB Europe Transparency and Consent Framework. As is usually the case, we had many interested attendees who were keen on learning more. While we usually do our best to make these as interactive as possible, we were simply overwhelmed with questions and had to skip over quite a few to be able to remain on schedule. For this reason, we have decided to answer the questions in a series of blogs. This is the second blog in the series, where we deal with the technical questions about the Framework. Upcoming blogs as part of this Blog Series will cover both policy and legal questions.

What do you mean by disclosing vendor permissions and requesting user consent? How is this done via the publisher?

The IAB Europe Transparency & Consent Framework is designed to enable publishers to (i) disclose the vendors who will be processing personal data when a user accesses the site; (ii) disclose the data processing purposes and associated legal bases for which and under which the vendors are processing personal data; (iii) request consent on behalf of those vendors who are relying on consent  as their legal ground for processing for one or more data processing purposes; (iv) store the user’s consent choices; and (v) transmit the user’s consent choices to upstream vendors. We are moreover working on enabling publishers to send a specific signal about whether they have established transparency about a vendor’s processing of personal data on the basis of a legitimate interest. As lawful processing requires transparency and a lawful basis (such as consent), and publishers are responsible and therefore in control of who is permitted to lawfully process personal data consent signals, and other signals sent through the framework are in essence doubling as permissioning signals. Publishers provide transparency and request and obtain user consent through a user interface managed by a Consent Manager Provider (CMP), operated by either a third party on their behalf or by themselves.

To learn more about how CMPs work and how information is transmitted in the Framework read the FAQ here.

“I get that OpenRTB has a field, but what about 3rd party tags pasted into various ad servers? It seems like no ad server has macros for the DaisyBit. Are you working on this?”

Yes, the Tech Lab has developed a URL-based consent passing spec that can support some non-OpenRTB implementations, and this is an open area to improve options for downstream vendors. Join the IAB Tech Lab’s GDPR working group and help us solve this! In the absence of standardized methods of transmitting the Daisybit outside of OpenRTB and URL-based methods, vendors are responsible to ensure they can transmit the Daisybit through whatever means they have available.

Browsers such as Safari are limiting cookies – how does that affect the IAB Europe Transparency & Cosnent Framework?

The Transparency & Consent Framework does not dictate the way in which consent signals are stored. The specifications standardize the data format in which consent signals are stored as well as the interaction with the consent signal, e.g. how to obtain it using a standard API. As such, the Framework allows storing consent signals in any way suitable and does not depend on cookies. However, most implementations on desktop today rely on third-party (global consent) or first-party (service-specific consent) cookies to store a user’s consent choices. On mobile, a user’s choices are stored in local app storage.  Safari Intelligent Tracking Protection (ITP) may impact cookie-based implementations of the Framework, particularly global consent implementations that rely on third party cookies. Service-specific consent implementations that leverage first party cookies are less affected. Nevertheless,  the IAB Tech Lab will be looking into solutions and strategies to account for ITP limitations in future.

“For transmitting the Daisybit string from party to party, I often see the OpenRTB protocol referenced as the required specification, but oftentimes vendors communicate via direct URLs with query string parameters. Is the query string passing guidance an official component of the IAB Europe Transparency & Consent Framework or is it purely an implementation suggestion?”

The IAB Tech Lab has published a specification for URL-based passing of consent, available on the Framework specification repository here: https://github.com/InteractiveAdvertisingBureau/GDPR-Transparency-and-Consent-Framework/blob/master/URL-based%20Consent%20Passing_%20Framework%20Guidance.md. In situations where URL-based passing is used, it should be implemented with this guidance.

Is it correct that in the case of OpenRTB Exchanges, the Exchange is not expected to protect the requests and the responses based on the payload for consent being passed along?

This is not correct. The Framework Policies only permit a Vendor to transmit personal data to downstream Vendors, for example in the context of OpenRTB, if they have reasonable reliance on that downstream Vendor’s having an appropriate legal basis for processing that personal data. This may be done on the basis of a signal in the context of the Transparency & Consent Framework but Vendors may have other mechanisms to rely on one another’s legal bases.

Why can’t pubvendors.json and CMP be combined into a single code based to account for both?

Early working group discussion explored combining publisher controls and consent preference signals. We determined that the large payload this would require was not appropriate, considering that publisher controls would not change on a per-bid-request basis. Also, the meaning of the signals can be kept distinct between user-preferences (in the consent string) and publisher-preferences (in the pubvendors.json file).

How do interested parties or individuals come to the Lab Tech Group with suggestions?

Proposals, feature requests, and bug reports are very welcome! The GDPR Technical working group at IAB Tech Lab stewards the technical specifications for the Transparency and Consent Framework. IAB Tech Lab members are welcome to join this group. More information available at https://iabtechlab.com/about-the-iab-tech-lab/join-the-iab-tech-lab/

Is it a must to store consent string on `consensu.org` domain? In case if third-party cookies are disabled, what to do?

It isn’t a requirement to store the consent string on consensus.org. Consent can either be stored on a first party cookie (publisher-specific), or on the consensu.org domain as a third-party cookie. Indeed, it is possible to store them outside of cookies altogether! The publisher/CMP can thus choose. Where third-party cookies are disabled, the publisher will not be able to recognize the user, so it may create a user experience issue for that site visitor as the CMP would ‘forget’ that user’s consent status. Publishers could consider informing users about this possibility or, more drastically, refuse access to users who do not allow third parties since this would also impact the ability to leverage ad space on its site.

Blog Series: What you always wanted to know about the Transparency & Consent Framework (TCF) / Part 2

On September 25th, we held a 2.5-hour long webinar providing a Complete Overview of the IAB Europe Transparency and Consent Framework. As is usually the case, we had many interested attendees who were keen on learning more. While we usually do our best to make these as interactive as possible, we were simply overwhelmed with questions and had to skip over quite a few to be able to remain on schedule. For this reason, we have decided to answer the questions in a series of blogs. This is the second blog in the series, where we deal with the technical questions about the Framework. Upcoming blogs as part of this Blog Series will cover additional technical questions, as well as policy and legal questions.

What about processing batch file data and not real-time requests? Do you actually need the consent string in the batch data file or can you here rely on a DPA with the data provider?

The Consent String, or daisybit, should be read in each bid request for each unique impression opportunity when passed over real-time bidding (OpenRTB).

Do users of the IAB Europe Transparency and Consent Framework have to provide a specific cookie that they want to investigate for a consent status? Could you clarify how would the investigation work?

The individual will be presented with a user interface (operated by a CMP, displayed on a publisher website page). The individual will then select their consent preferences, and this information then gets stored as a cookie (either as a third-party cookie or site-specific cookie). The user is not expected to investigate the literal cookie itself, but a CMP should offer a way for the user (consumer) to re-select their consent preferences, thereby triggering an update to the cookie that has the consent string record.

Can you define what is covered by ‘open source standard’? Is it a tech standard or does it include language and contractual structure?

The IAB Europe Transparency and Consent Framework has open source technical standards managed by IAB Tech Lab and includes a process of registration (including agreement to terms and conditions), allowing a company to express that they adhere to expected policies.

Well known examples of purely technical ‘open source standards’ include OpenRTB, VAST, or MRAID (each without a “framework” that requires corresponding terms and conditions). These technical standards have a system of community and governance to maintain and upgrade specifications to meet industry needs. Participants contribute to implementation guides, provide use cases, or propose new features. A governing body is able to commit to formal iterations and new versions of the specifications, providing structured pathways to updates.

How does the vendor know that the other vendor to whom it is transmitting the data has received the users consent?

All vendors taking part in the Transparency & Consent Framework are obliged to accept the Terms and Conditions, as well as fully adhere to the policies of the Framework. The first vendor in this scenario has to pass the ‘daisybit’ down the chain upon receiving it themselves, and it is up to the vendor down-stream to appropriately respond to the information therein and pass it further down the chain where applicable.

There is currently no technical signal to indicate that consent has been read or applied, though it is a useful suggestion that could be considered as a feature to be included in future updates to the TCF infrastructure.

Is there any way for the signal of “legitimate interest” to be assessed by the IAB Europe Transparency and Consent Framework or will the signal be accepted as it was sent by the CMP?

Signaling of a ‘legitimate interest’ legal basis through the daisybit has been explored by the technical working groups. They determined at the time that the daisybit payload would be overloaded with this extra bit of information since it would effectively double the size. In turn this would add latency and mix intended signals in the Framework.

The Global Vendor List allows a vendor to declare their purposes and legal bases. The consent string should contain information about the user’s consent preferences, and separately, the pubvendors.json file can contain information about the publisher’s permissions for vendors, and for their vendor’s legal bases.

We are still exploring ways to consolidate all the information about whether the user’s data can be processed in future, but with the current iteration we have to rely on a solution which has a consent string on the one hand, and uses pubvendors.json to declare the reliance on legitimate interest on the other.

Is there a published technology roadmap? Is there going to be a defined update/release cycle for enhancements?

There are currently a few new feature updates that are being prioritized, and shared publicly, including pubvendors.json v1.1 finalization, adding security/authentication to the Framework, and efficiency updates. Members of the IAB Tech Lab GDPR working groups have full access to backlog and detailed roadmap of proposed features.

There seem to be many “private CMPs” who have not obtained their own CMP ID and are generating and transmitting consent strings with the invalid CMP id or 1 (what’s in the IAB source code”. Is there any effort underway to eliminate these invalid consent sources?

We have partnered with The Media Trust, who are developing a self-testing tool for CMPs to assess whether their CMP implementation is compliant with the policies of the IAB Europe Transparency and Consent Framework. This will allow current CMPs to improve their products to better fit the standards. This is the first step in a larger effort to validating CMPs, and in that process, we will more diligently update the list of CMPs on www.advertisingconsent.eu, including delisting CMPs that are found to be operating in a non-compliant way.

It should also be noted that, as a matter of the policies, vendors who receive a daisybit from an invalid CMP ID are required to ignore the signal and not act any further on the bid request it is appended to.

Blog Series: What you always wanted to know about the Transparency & Consent Framework (TCF) / Part 1

On September 25th, we held a 2.5-hour webinar providing a Complete Overview of the IAB Europe Transparency and Consent Framework. As it is usually the case, we had many interested attendees who were keen on learning more. While we usually do our best to make these as interactive as possible, we were simply overwhelmed with questions and had to skip over quite a few to be able to remain on schedule. For this reason, we have decided to answer the questions in a series of blogs. This is the first blog in the series, where we deal with the ‘big picture topics’ surrounding our Framework. The next blogs in the series will delve into the technical questions, and to conclude we will answer policy-related questions about the Framework.

Some of these questions have been edited for clarity, or we have answered to topics which were asked about several times

Please provide definitions for some of the acronyms and terms used:

TCF: Acronym for the Transparency & Consent Framework.

EDAA: The European Interactive Digital Advertising Association. This organisation adheres the self-regulatory framework for online behavioural advertising (‘the OBA Framework’).

OBA: Online Behavioural Advertising. The practice of making use of data about user behaviour online to determine more relevant advertising. The EDAA’s OBA Framework is a tool that allows users to get information about this practice and to opt-out of receiving this targeted form of advertising but does not equate to an objection to data processing as provided for under the GDPR’s data subject rights.

Daisybit: This is the information containing information about consent that is given (or not given) for the various purposes standardised by the Framework as well as for different vendors. The information is compressed into a ‘bit-string’ which is daisy-chained through the online advertising supply chain, hence the name ‘daisybit’.

SSP: Supply-Side Platform. Also referred to as the ‘sell-side’, these are platforms that facilitate the sale of ad space.

DSP: Demand-Side Platform. Also referred to as the ‘buy-side’, these platforms help brands and agencies buy ad space.

Publishers: A publisher in the context of our Framework is any consumer-facing website or application, also referred to as the ‘first-party’. It does not refer exclusively to news publishers.

On Google integration with the IAB Europe Transparency & Consent Framework:

Google has stated during the webinar that it plans to interoperate with the Framework once the current work on updating the Purposes, Policies, and introducing Pubvendors.json is complete. This is so that they avoid integrating with the current Policies and Purposes only to have to transition to the revised ones almost immediately.  Our expectation is that Google will make an announcement over the next 3-4 weeks and will actually be implementing the TCF as from January 2019.

IAB is supporting the Transparency and Consent Framework as well as OBA Framework (EDAA). How do these two initiatives talk to each other? Does the first make the later redundant?

The EDAA’s OBA Framework does not help companies achieve compliance with EU data protection law. It is a self-regulatory framework providing so-called “enhanced notice” through an icon and allowing users to “opt-out” of behavioural targeting. Neither the transparency provided through “enhanced notice” nor the “opt-out” meet the relevant requirements under European data protection law.

The IAB Europe Transparency & Consent Framework (TCF) is a Framework designed and intended to help companies comply with obligations arising from EU data protection law, such as transparency, lawful processing, and accountability. Using the TCF, first-parties can enable third-parties to process user data on one of the legal bases of the regulation. The Framework standardises the presentation to users’ third-party data processing requests that require “informed” consent for data processing. The Framework enables “signaling” of user choice across the advertising supply chain. It is open-source, not-for-profit with consensus-based industry governance led by IAB Europe with significant support from industry parties and the IAB Tech Lab, which provides technical management of the open-source specifications and version control.

The two Frameworks are entirely separate and do not interoperate.

On meetings with Data Protection Authorities:

We have been meeting with European data protection authorities to present the IAB Europe Transparency & Consent Framework and to engage in an open-ended conversation to aid in our joint goal of helping companies in the online media and advertising business to comply with European data protection law. Our meetings with the DPAs are private, meaning that we will not be sharing any specific responses or feedback publicly. We hold meetings with those DPAs where we have established contact and who show an interest in meeting with us. It is therefore possible we have not met with DPAs in your jurisdiction – to date we have met with five different DPAs in Europe.

Does the IAB Europe Framework align or reference to some of the key requirements as detailed in the WFA manifesto  earlier this year?

While the IAB Europe Transparency and Consent Framework does not make any direct reference to the requirements of the World Federation of Advertisers’ (WFA) Manifesto for Online Data Transparency, we believe that the TCF is a critical tool in achieving the manifesto’s view that a sustainable digital advertising ecosystem requires the engagement and commitment of all stakeholders to practices that put consumers’ needs first, providing transparency, control, and accountability.

I am a vendor that’s included in the Framework. Could you clarify – how is the framework supposed to benefit me as a vendor?

The Framework allows Vendors to be disclosed to users, establish a lawful basis for processing, and receive a signal that allows it to verify that transparency and/or consent have been established. It is unlikely that in absence of a technical framework Vendors would be able to reliable comply with the law.

Minor Update to the Policies of the IAB Europe Transparency & Consent Framework relating to CMPs

IAB Europe has published a minor change affecting the Policies of the IAB Europe Transparency & Consent Framework (“Framework”) on Wednesday, 3 October 2018.

The update exclusively addresses a paragraph under the heading “Working with Vendors” in the “Policies for CMPs”, that could have been understood as requiring CMPs to work exclusively with Vendors who participate in the Framework.

Such an exclusivity paragraph is inconsistent with the “Policies for Interacting with Users”, which stipulate that the UI must prominently distinguish between Framework participants and others and avoid confusing or misleading users about the Framework participation of any of the disclosed parties.

To resolve this inconsistency and address confusion it has caused, IAB Europe deleted the exclusivity language under the heading “Working with Vendors” in the “Policies for CMPs”, and replaced it with the following wording:

“If a CMP works with Vendors who are not registered with the MO, the CMP must make it possible for users to distinguish between Vendors registered with the Framework, and those who are not. CMPs must not mislead others as to the Framework participation of any of the Vendors who are not registered with the MO.”

No other changes have been made to the Policies at this time. The new Policies Version 2018-10-03.2a replace the previous Version 2018-04-25.2.

Amsterdam eWeek & IAB Nederland – The IAB Europe Transparency and Consent Framework TownHall – 8 October

Join the Townhall organised by IAB Nederland on 8 October during the Amsterdam eWeek, a week-long festival shaping the future of digital business, to learn and discuss the IAB Europe Transparency and Consent Framework with industry experts. They will explain how the Framework operates and how it can be implemented.

The panel discussion will include the following speakers: 

  • Matthias Matthiesen – Director Privacy & Public Policy at IAB Europe
  • Tim Geenen – Member of the Board of IAB Netherlands, CEO & Founder at Faktor
  • Jeroen Beeke – Digital Strategy Director at Initiativ
  • Marco Kloots – CEO & Founder at Platform161

Practical information: 

  • Date: 8 October
  • Time: Walk-in 08:30 / Start 09:00-11:00
  • Note: The session will be in English
  • Location: B.Amsterdam

To join this event, buy the tickets here & visit the IAB Nederland website here.

Are you a member of IAB Nederland? Please note: we apply a no-show fee* of € 50 for the costs incurred for free IAB Nederland Members tickets.

No-show fee: if you are unable to attend, cancel your free ticket or send an e-mail to info@iab.nl. Free cancellation is possible up to 24 hours before the event. Less than 24 hours before the event, IAB Nederland will apply a no-show fee of 50 euros.

IAB Europe Webinar – A Complete Overview of the Transparency & Consent Framework – 25 September

Join this webinar to gain insight into the IAB Europe Transparency & Consent Framework.

IAB Europe Panel at DMEXCO: Taking stock – the impact of Europe’s new data protection – 12 September

Join the IAB Europe panel at DMEXCO on 13 September 2018 on Day 2 at 9.45 – 10.15am on the Debate Stage. It will be moderated by Townsend Feehan, CEO, IAB Europe and will discuss the impact of GDPR several months after its enforcement date, as per the description below:
 
Taking stock – the impact of Europe’s new data protection rules four months on
In May 2018, the EU’s long-awaited General Data Protection Regulation became enforceable, following a two-year transition period. The Regulation is supposed to empower consumers, giving them more transparency and control over how their personal data are processed, and to make life easier for European companies, who in theory now have one harmonised set of rules for a market of 450 million users. Four months on, is the vision being realised? Will Europe lead the world in the development of innovative privacy-enhancing technologies, as the GDPR’s supporters have promised? Or will it struggle to cement its Digital Single Market because of contradictions inherent in the Regulation and between the Regulation and the proposed ePrivacy regulation? How has GDPR impacted the bottom line?
In addition to this seminar, IAB Europe will also have a booth at DMEXCO so make sure to schedule a meeting or drop by.