Overview
As a reminder, clients that wish to comply with the General Data Protection Regulation (GDPR) - Transparency Consent Framework (TCF) v2.0 policy must make all necessary changes according to IAB timeline and finish by August 15, 2020 . IAB Europe Transparency and Consent Framework (TCF) intends to help the digital advertising industry interpret and comply with EU rules on data protection and privacy (GDPR, ePD).
Issue with TCF v2 TC strings
We have identified a third-party technical issue involving the implementation of the IAB’s Transparency & Consent Framework v2 by some CMPs.
The issue relates to TCF v2 PublisherTC strings being passed to us by CMPs, which, for the majority of CMPs sending us these strings, appear to have been incorrectly configured or are yet to be enabled, with the consequence that the PublisherTC strings do not inform us of the legal basis relied upon for processing purposes.
They instead just include what appears to be a “placeholder” string, which is the default setting for a PublisherTC string unless it is amended. Unfortunately, the coding of the “placeholder” PublisherTC string is the same as the coding for a PublisherTC string which is configured correctly and indicates that no consent has been given and objections have been raised to processing on the basis of legitimate interests (an “objection” string). We therefore cannot distinguish between a “placeholder” PublisherTC string and an “objection” PublisherTC string. We are reasonably certain that this must be an error because some CMP’s are sending us 100% “placeholder/objection” PublisherTC strings.
As a data processor, FreeWheel relies on our publishers’ legal basis for processing personal data under GDPR, so this is a significant issue. As “placeholder/objection” PublisherTC strings show no indication of the legal basis relied upon, in accordance with IAB guidelines our platform interprets this “placeholder/objection” section as meaning that there is no legal basis for our key processing activities. This means that the following functionalities of our platform are either restricted or disabled:
- setting cookies;
- frequency capping;
- geo targeting;
- audience targeting;
- forecasting; and
- information stored in logs.
If you are our customer and believe you are or might be impacted by this technical issue, you will receive further details on this issue as well as suggested next steps for remediation.
Additional Resources
For more information regarding TCF v2, please see the resources below: