Post on 04-Jul-2020
transcript
Tom Halank @ Digital Innovators‘ Summit 2019
IAB TCF & upcoming challenges with
consent management
Agenda
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▪ GDPR & ePrivacy in a nutshell
▪ What is the IAB TCF and how does it work? What’s in for me?
▪ How Axel Springer deals with the upcoming challenges
▪ Audience discussion
Axel Springer at a glance
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Note: Revenue and EBITDA present the results of continuing operations; Unique visitors desktop + mobile, based on own calculations via ComScore.
Founded in 1946 by Axel Springer
Headquartered in Berlin
Listed since 1985
Shareholders: family >50%
Active in >40 countries
Revenue 2018: 3.2bn €
EBITDA 2017: 738m €
Digital reach: ~200m UVs globally
GDPR and ePrivacy Regulation: Don‘t mix it up!
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ePrivacy
RegulationGDPR
GDPR & ePrivacy in a nutshell and status in Germany
GDPR says
Legal basis can be consent
(opt-in), contract OR
legitimate interest
Consent not mandatory
But GDPR also says
Existing national laws based
on old ePrivacy Directive
(which requires consent)
remain in force
Consent is required
German law says
Based on old ePrivacy Directive,
Germany has opt-out solution*
European Court of Justice to
clarify if OK**
Consent is not required
The mechanics are
discussed
controversially.
Other EU member
states might have a
need for consent.
Prohibition of Cookie Walls
(“Kopplungsverbot”)
You can’t force readers to opt-
in. Dutch Privacy Regulator:
Publishers have to offer same
content w/o Cookies.*
“Browser Supremacy”
Even if your reader grants a
legally valid opt-in, negative
browser settings will prevail.
Timeline ePrivacy Regulation
Drafts since Jan, 2017
Scheduled for May 2018 (GDPR).
No final draft yet.
Further decisions after elections
of EU Parliament in May 2019.
eP
rivacy
GD
PR
* Sec. 15 (3) TMG
** ECoJ („EuGH“)
C 673/17
* https://techcrunch.com/2019/03/08/cookie-walls-dont-comply-with-gdpr-says-dutch-dpa/
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What is the IAB TCF?
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Transparent
information
User consent
requirements
Which companies
process which data
and for what purpose
on a website?
Signal reliable
information about user
decisions on Consent
or Legitimate Interest
into the ad tech chain.
+
▪ IAB Transparency & Consent Framework
▪ Designed to be flexible and accommodate different publisher, vendor and advertiser needs
centering on transparency, control and choice
▪ Common „communication standard“ everybody shall speak
Conformity
Allow GDPR
conformity for all
participants in the
digital advertising
ecosystem.
=
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Source: Kindly provided by IAB Europe
26.03.2019 IAB TCF & upcoming challenges with consent management8
Source: Kindly provided by IAB Europe
What the TCF solves given this setup
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▪ Enables publishers to decide on which partners they want to work with
▪ Provides transparency by company and data processing purpose in a standardized way(for example: the creation of interest profiles, selection of (relevant) ads or content, measurement)
▪ Offers users choice by company processing data and by purpose of data processing
▪ Creates actionable signals backed by enforceable policy that seeks to ensure data is only
processed if lawful
Source: Kindly provided by IAB Europe
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Modular principle
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Transmitting consent choices
How the consent signal is transmitted down the ad tech chain
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Based on IAB TCF we‘ll experience a new consent
management structure
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Global Vendor List PurposesConsent
ForwardingPublisher Controls
Connection to
Consent Manager
Provider (CMP)
Review all vendors
that want to
participate in
programmatic bidding.
Choose for which
purposes vendors can
collect and process
data.
Pass down opt-in /
opt-out to vendors
through the ad tech
chain.
Control which vendors
to work with also
when legitimate
interest is legal basis.
The Opt-in Layer is
the user interface /
CMP in case of AS.
Optimizations in TCF v2
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IAB TCF is a "technical framework" that supports all game types,
but does not predefine them.
▪ Supports Consent & Legitimate Interest as legal bases
▪ 10 granular purposes + 2 special purposes (technical ad delivery + security & fraud)
▪ Separation of Advertising and Content
▪ Separation of Data Collection and Data Usage
▪ Separate Purposes for Measurement
▪ Granular Publisher controls to define which Vendor is allowed to work under which Purpose
▪ Grouping of Purposes into so called “Stacks” possible
Recap: What’s great about TCF?
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Control over the vendors enabled by publishers.
Transparency into the supply chain for consumers & publishers.
An auditable consent trail that gives all supply chain members confidence by providing a
more efficient disclosure mechanism, enabling companies to ”know” rather than “assume”
their consent status with a user.
AS’ solutions on how to face GDPR and gain consents
OIL
Pseudonymous Traffic
o Temporary consents
o Opt-ins either site-wide or
group-wide for AS
o AS internal data
o Quick to deploy
Logged-in Traffic
o Persistent consents
o Consents group-wide for
Verimi partners
o Requires registration
models
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Technical Overview OIL
In order to control trackers that come onto the
website via advertising, OIL can forward opt-
out/opt-in information via the technical standards
of the IAB Framework down the ad tech chain.
The IAB Framework’s goal is to provide
transparency and control regarding tracking
technology in advertising both for the publisher
and the end user.
AS Opt-in Layer
Website
Tags via AdsTags on Website
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3
2
Addresses both tags on websites and
tags via ads
Configurable text & design and
flexible positioning
Enables GDPR compliance. It is both
applicable for Consent as well as
Legitimate Interest scenarios.
Covers various consent categories
AB-Testing capabilities
Provides Cookie Preference Center
Integration in Privacy Policy
OIL – Example & Functions OIL
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Strategic rational for building an open source solution
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Core business directly affected Harness synergies
Control over judicial transposition
Effective involvement in IAB TCF
Support industry standardization
Motivate publishers to built up in-house expertise
IN-HOUSE DEVELOPMENT OPEN SOURCE SOLUTION
Takeaways: What I want you to remember
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1. Adaption of IAB TCF is a great opportunity for the digital world to
establish a market-wide common communication protocol to
tackle the regulatory challenges on consent and data usage.
2. Thus, it’s interesting for you as well!
3. Implementing the framework is not a legal-only topic but must include
also tech, product and business.
4. It‘s beneficial for everybody if every market participant becomes
part of the TCF!
THANK YOU!
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