On 30 October, the French data protection authority (CNIL) published a notice declaring that French start-up company VECTAURY failed to meet conditions for valid consent under data protection law and ordering the company to cease processing geolocation data for advertising purposes without an appropriate legal basis. VECTAURY has been ordered in particular to ensure it obtains GDPR-compliant consent from users of the apps from whom VECTAURY receives real-time bidding opportunities before processing these users’ data moving forward. In addition, the CNIL ordered VECTAURY to delete all data obtained on the basis of the invalid consent.
Some commentators have suggested that VECTAURY ended up in the CNIL’s cross-hairs because it built a Consent Management Provider (CMP) that implemented the IAB Europe Transparency & Consent Framework (TCF). VECTAURY registered itself as a TCF CMP in May of this year.
The suggestion is wrong: the CNIL’s investigation started prior to VECTAURY ever registering itself as a TCF CMP. In addition, on many of the points on which the CNIL considers VECTAURY’s conduct to have violated the General Data Protection Regulation (GDPR), it also violated the TCF’s policies. Indeed, had the company adhered to those policies, not only would it have been better-placed to meet its obligations under the law, but some of the most problematic of the concerns raised by the CNIL would have been addressed.
In its notice, the CNIL finds that in two scenarios VECTAURY did not have a legal basis for the processing of personal data under the GDPR. First, where VECTAURY collected and processed geolocation data from mobile app users of mobile apps via its SDK, and a second where it collected and processed personal data received in real-time bids for inventory on mobile apps.
The legal basis claimed by VECTAURY was the consent of the users whose data was processed. The CNIL’s notice declares that in both scenarios, VECTAURY and its partners failed to meet the conditions for valid consent – and as a result it could not serve as a legal basis for processing.
In the first scenario, where VECTAURY collected and processed geolocation data from mobile app users of mobile apps via its SDK, the CNIL noted that default Android OS or iOS notification windows asking for the user’s permission for geolocation data to be collected did not allow VECTAURY to obtain valid consent. VECTAURY then developed a CMP built on the basis of the TCF as a suggested way forward which it submitted to the CNIL. The CNIL opined that while VECTAURY’s CMP would improve transparency for users, it still did not meet the CNIL’s standard for valid consent, because it (a) failed to ensure that users were appropriately informed of the identities of companies that wished to process their data, and (b) failed to ensure that consent was expressed by a clear, affirmative action.
The notice states that in some circumstances, users were not made aware of the fact of VECTAURY (or other companies) seeking consent to process their data at all, and in a consent request UI developed by VECTAURY the default settings didn’t require users to toggle the settings or take some other action in order to convey their agreement.
In both cases, VECTAURY’s CMP also failed to meet its obligations under the TCF’s policies.
In order to be valid under the GDPR, consent must be “informed” and “specific”. Users need to know which companies wish to process their data, and for what purposes. Other information disclosures must accompany this transparency about who is requesting consent, and why. If VECTAURY's partners failed to disclose to their users the fact that VECTAURY was one of the companies seeking consent to process their personal data, the conduct of both the partners and VECTAURY was clearly non-compliant. The TCF’s policies require that a consent request conveys to the user both the identities of the companies who wish to seek to process a user’s personal data, as well as the purposes of the processing in a way that enables the user to appreciate that each purpose and company are distinct and separate from one another.
On the “affirmative action” item, the position is also unambiguous. VECTAURY appears to have implemented a consent UI in which a user would be considered to have consented to data processing despite taking no affirmative action of any kind to convey agreement. This is a clear breach of the GDPR and of the TCF’s policies, both of which require a user to affirmatively consent.
Some of the conduct that the CNIL interpreted as being in breach of the GDPR had to do with how information was presented in the UIs of the apps with whom VECTAURY partnered. Here the CNIL relied on opinions from the Article 29 Working Party of European data protection authorities (DPAs) – and in some cases on its own interpretation of that guidance – to arrive at its finding of illegality.
For example, the CNIL found that the UI in the apps did not inform users of all the controllers who were seeking consent for data processing at the exact moment – or in the exact UI layer – as the request for consent. Similarly, detailed information on the data processing for which consent was being requested was not provided simultaneously. Also, the CNIL found the language used to explain to consumers why data needed to be processed to be hard to understand.
These are more subjective items on which reasonable people can disagree. In the case of presentation to users of the details of the controllers seeking consent simultaneously with the consent request itself, CMPs need to make a judgement about how much information users can assimilate in a single screen. It appears that the UI that VECTAURY implemented in the CMP it recommended to its app partners required the user to click on several links in order to navigate to the list of companies that wished to process their data (including VECTAURY). Arguably a better implementation would have reduced the number of clicks required. Indeed, the TCF’s policies require a link to be provided to the list of companies and for the processing purposes to be disclosed on the first layer of a consent notice.
In the case of the definitions of data processing purposes for which user consent was being sought, here the CNIL clearly has a point. But striking the right balance between specificity and granularity, on the one hand, and simplicity and ease of comprehension, on the other, is not easy. The definitions that seem to have prompted the finding of illegality include some of the five definitions currently included in the TCF. They are being revised, in a process that began during the summer following our first meetings with DPAs – including the CNIL – to present the Framework. One objective of the revision is to make the definitions easier for users to understand.
Perhaps more importantly, we need to consider the best way forward for the Framework and for users on the points where the GDPR itself is silent or unclear, including how to reconcile the apparently conflicting imperatives of ease of user experience, on the one hand, and timely and complete information, on the other, when it comes to information disclosures to users in the context of consent requests.
The CNIL’s discussion of the second scenario where VECTAURY obtained and processed of data received through bid requests, has also made it evident that we will have to do more to support proper implementations by CMPs of the rules of the Framework and the GDPR. This is imperative if the TCF’s signals are to be trusted by the companies who rely on it to mean that appropriate transparency has been provided to users and valid consent has been obtained. The Framework’s signals need to be reliable since the CNIL confirmed that it expects a company to be able to ensure and demonstrate that the consent it relies on is valid at its source but putting in place contractual provisions does not meet the requirement of demonstrating that consent is valid. As it is entirely unfeasible for millions of websites and apps to be individually vetted by thousands of technology partners, we need a trusted Framework the proper implementation of which can ensure and signal that transparency and consent have been established in line with the GDPR.
We welcome the prospect of discussing these issues with the CNIL and with other DPAs over the coming months.
Having been made aware of a possible breach of the TCF’s policies by VECTAURY’s CMP, we will launch a review of the same. We expect to support the company in its efforts to adhere to the TCF’s policies, and accede to the CNIL’s order.
For more information on TCF roll-out and GDPR legal compliance for the digital advertising industry, please write to us at matthiesen@iabeurope.eu or feehan@iabeurope.eu, or check out https://advertisingconsent.eu.
Phil Sumner, Global Media Insights Director, Teads
Growth of digital advertising is being held back; that is one of the main conclusions I draw from the Digital Brand Advertising and Measurement Report recently released by IAB Europe. Results indicate that there is still a ‘significant knowledge gap within advertisers’ who have unmet measurement priorities - many of which (I believe) have been solvable for some time. On the plus side, there is evidence that good progress is being made, for example, in France, where advertisers lean heavily in to the debate and have helped push things forward but examples like this are few and far between.
I believe responsibility for this is shared; agencies and publishers should be obliged to communicate out, from our industry, the solutions available today. Equally, and perhaps most critically, I believe that advertisers would benefit from leaning in more to our industry; for example, being more vocal when pushing back on things such as publisher-specific measures which create confusion and erode confidence. Whilst it’s great to have the likes of P&G being so vocal over the last 18 months, they should be supported more openly by their fellow advertisers to create sustainable momentum towards long term change in our industry. Ultimately all sides have a responsibility to move this agenda forward and unless we do in unison, we will continue to make comparatively slow progress and that’s a missed opportunity for everyone.
To use an analogy; if progress in digital measurement is akin to Humankind's’ mission to visit and colonise Mars then by this point, we should have set up an early settlement with the foundations to grow in to a thriving city. Instead we’re stuck on earth, arguing over whether we should be going to Mars in the first place and allowing myriad of space businesses to make spurious claims as to why they are best set for the job without proper foundation. NASA is nowhere to be seen. The net result? We struggle to get beyond the Earth’s orbit.
Our collective slow progress is laid bare by three of the top five advertisers’ priorities highlighted in the report:
These are all measurement fundamentals and in reality, there have been solutions available for many years. The measurement discussion in 2018 should be around improving and honing the definitions and standards within functioning digital trading currencies built on consensus as opposed to ensuring that impressions served are viewable. Whilst industry players may disagree on the minimum threshold for viewability, its option to be included within the definition of a valid impression should be table stakes. Measurement companies have actually made great strides in recent years for reliable, timely and accurate cross device measurement, so the capabilities are there but are largely being under-utilised.
By taking advantage of our slow industry progress, we’ve seen opportunistic behaviours, manifested in the emergence of separate data sets put in to the market that don’t stand up to third-party scrutiny. The pervasive long-term problem this creates is a perceived lack of trust for our industry as a whole. The company I represent (Teads) has and will continue to take the position of being measurement agnostic, championing transparency and following the needs of our clients (advertisers and agencies) and the media markets in which we operate. What is demanded by our clients or the markets in which their media teams operate may not always be our preferred choice for measurement (and we may feel that other measures represent us better) but like any successful, well-functioning industry, some self-interest needs to be traded for the greater good.
But it’s important to make and re-state the case: good quality, industry agreed measurement standards will lead to growth, so we can’t lose sight of this and we should highlight where this has worked before. There is evidence aplenty from within the media industry of currency acting as a growth driver. Cinema advertising in the US in 2003, outdoor advertising in the UK in 1995. Within digital, markets like France and Italy - who I see as being closest to fully functioning digital consensus - have comparatively a much lower dependence on search than others (such as the UK).
One of the key drivers of implementing a successful measurement solution in France has been the involvement of French advertisers, through their trade body, who drove the industry towards agreement on a comparable GRP with TV and didn’t let up. Whilst there have been struggles in France to fully adopt the definitions, the conversation has moved on significantly, as has the sophistication of the standard measures expected and accepted in the marketplace.
We still have a long way to go even in the markets like France, but the good news is that many of the unmet measurement priorities are solvable today. Like a three-legged stool, all three legs need to be in place for the stool to stand. The same applies to reaching a consensus on measurement; everyone needs to come together.
Natasha Morris, Director, Publicis Media
Today, the path towards transformation is led by technology, so how can implement technology in a way that is to the benefit of talent through learning and development? Natasha Morris at Publicis Media shares how the Global Learning Strategy team are using technology to invest in talent and fuel transformation of the business.
Make space
Creating an online space was the most effective way to foster curiosity amongst our company. We span across numerous countries and time zones, so making a place to for people to come together where everyone could access it was important.
We created the Publicis Learning platform to educate teams on the ever evolving media landscape in the most efficient and effective way. The platform hosts bite sized micro online learning courses that introduce concepts and topics to the end user in a modular way. There’s even a localisation manager working with international teams to ensure content is translated and localised for their markets.
This has meant that everyone has access to expert content and an understanding of complex media theory wherever they are in the world at a time that suits them.
Use different mediums
We have advertising experience ranging from decades of active service through to school leavers who join the business, so it is important to suit learners who are used to learning in different ways.
The content is built to appeal to everyone: there are interactive elements where users must manipulate the content, voice overs and navigation panes to help visual, print and aural users and gamification to help build and reinforce topic areas.
Lectures and the classroom are still important but think about the different ways in which you can learn. If you always run a PowerPoint presentation, then maybe every ten minutes have audience interaction or a pop quiz.
Empower your teams
Learning shouldn’t be the sole responsibility of one team within your organisation. The business needs to foster curiosity and empower people to take control of their learning. We talk a lot within Publicis Media about being cross-skilled, so we encourage everyone to actively participate and control their progression.
At each stage in an employee’s career, we have created special extended courses to help grow employees to the next step up. It’s important to recognise your future leaders aren’t in the board room, they could be on the grad scheme or taking their first step into managing a team! So make time to learn for everyone in your organisation.
If we are truly going to transform as an industry, a huge part of that needs to come from within your organisation. The people are the ones who are going to ensure you achieve the vision you want over the next few years, so take some time to think about their progression too!
Turning Paris into the AdTech Capital of the World for a day!
On November 30th, from 8:30am to 5pm at the Palais de Tokyo in Paris, the Interactive Advertising Bureau France will organize a new summit dedicated to the digital advertising ecosystem and its technologies, in partnership with the IAB Tech Lab. The Tech Lab is an independent international organization, branch of IAB, which sets the international digital advertising standards (https://iabtechlab.com/).
IAB France aims to build on its international network and the expertise of its members and partners to explore the major themes of innovation in digital advertising that will define 2019 and beyond.
The AdTech Summit will include a stimulating series of interviews, keynotes, panels and exclusive workshops. Leaders and experts of digital advertising, its technologies and its regulation, will come on stage to share their operational vision on the major issues for the industry.
Among the speakers who have already confirmed their attendance:
Dennis Buchheim (SVP & General Manager, IAB Tech Lab), Jennifer Derke (Director of Product, Programmatic, IAB Tech Lab), Mark Timlin (Programmatic Trading Manager, BBC Worldwide), Simon Baker (Head of Digital & Programmatic EMEA, Bloomberg), Mathieu Morgensztern (CEO, Group M France and WPP France), Gautier Picquet (CEO, Publicis Media), Cédric Vandervynckt (EVP EMEA, Criteo), Sam Tingleff (CTO, IAB Tech Lab), Sylvia Tassan Toffola (VP, TF1 Publicité - Président of SRI), Jean-Luc Chetrit (GM, UDA), Denis Gaucher (CEO, Kantar Media), Régis Schultz (President, Monoprix)…
Registration to the AdTech Summit is free of charge for IAB France and IAB Tech Lab members.
An early-bird rate can still be secured by non-members until 16 November.
---
Press contact
Thomas Bordet, IAB France, thomas@iabfrance.com, +33 (0)1 48 78 14 32
---
About
IAB France (Interactive Advertising Bureau) is an association created in 1998 with a threefold mission, as it aims to structure the digital communication market, promote its use and optimize its efficiency.
IAB currently has 140 member companies, representing all the players in the interactive communication chain (publishers, advertising agencies, agencies, advertisers, research institutes, tech providers, etc.).
Through its publications, studies and events, IAB France is at the service of advertisers and their consulting agencies to help them integrate digital media efficiently into their global marketing strategy, and propose Standards, examples of professional practices to new players integrating the digital market.
The IAB is also a network of experts at the service of other professional organizations, institutions and media who are questioning the impact of the development of this new economic situation.
IAB France is an independent entity, part of the global network of affiliates of the Interactive Advertising Bureau.
IAB France’s Board is composed by Weborama, Ligatus, Smart, Le Monde Publicité, 366, Google, S4M, Konbini, Adways, Orange Advertising, Kantar Media, Leboncoin Schibsted, LinkedIn, Adverline, Sirdata, Ogury, Newbase, Graphinium, Adcleek, Deezer et Bayard Media Développement
The AdEx Benchmark H1 2018 Study reveals that mobile ad spend crossed the €10bn mark and is approaching a 50% share of digital ad spend. The latest European Programmatic Market Sizing Report published by IAB Europe and IHS Markit shows that more than half of programmatic display spend is in mobile formats.
Video grew by more than 4 times total display and now accounts for 30% of the display segment. This expansion of video has increased the total display’s share of the overall digital ad spend market.
Display advertising growth continues to outpace search[1]; display grew by 12.3% and search by 10.2%. Display reached over €10bn in H1 2018 representing 40% of total digital advertising whilst search accounted for 46%. Display advertising continues to experience strong growth in Central and Eastern Europe; in H1 2018 it grew by 17.9% compared to 11.2% in Western Europe. Indeed, the CEE region helped to drive the overall growth with an increase of 17% whilst the more mature markets in Western Europe experienced a growth of 9%.
Looking ahead IHS Markit estimates that digital ad spend will surpass €50bn in 2018.
Register below to download the full study
Brussels, 12 November 2018 - IAB Europe, in collaboration with IHS Markit, has today published the AdEx Benchmark H1 2018 Study revealing that digital advertising grew by 10% to €25.7bn in the first half of this year.
The Study reveals that mobile ad spend crossed the €10bn mark and is approaching a 50% share of digital ad spend. The latest European Programmatic Market Sizing Report published by IAB Europe and IHS Markit shows that more than half of programmatic display spend is in mobile formats.
Video grew by more than 4 times total display and now accounts for 30% of the display segment. This expansion of video has increased the total display’s share of the overall digital ad spend market.
Display advertising growth continues to outpace search[1]; display grew by 12.3% and search by 10.2%. Display reached over €10bn in H1 2018 representing 40% of total digital advertising whilst search accounted for 46%. Display advertising continues to experience strong growth in Central and Eastern Europe; in H1 2018 it grew by 17.9% compared to 11.2% in Western Europe. Indeed, the CEE region helped to drive the overall growth with an increase of 17% whilst the more mature markets in Western Europe experienced a growth of 9%.
Looking ahead IHS Markit estimates that digital ad spend will surpass €50bn in 2018.
Townsend Feehan, CEO of IAB Europe said, “The half year AdEx Benchmark Study provides an update on the status of the digital advertising market in Europe. It continues to confirm the growth of video and mobile advertising as marketers look to digital as a brand building medium.”
Anton Kopytov, Partner Technology Consulting, Mindshare and Chair, IAB Europe Research Committee said, "The latest AdEx study demonstrates an understanding in the market that consumers barely separate their digital and analogue lives, that digital factors into every channel and means of communication. The lines between traditional and digital are blurring driving the growth of cross-channel video strategies and resurgence of audio on multiple platforms, including desktop, smart TV and mobile devices. GDPR has had an impact on data-driven activations in first half of 2018 making key market players cautious, but the general impact has been positive in building trust in the digital industry and we see recovery in the second half of 2018. Overall outlook for the consistent market growth is positive both in the East and the West of Europe."
Daniel Knapp, Executive Director TMT at IHS Markit, said "Uncertainty associated with GDPR impacted advertiser confidence in most markets, causing slower growth in digital ad spend between March and June. Demand conditions are set to improve in the second half of the year as market participants navigate the regulatory environment. Demand for video advertising and search remained strong in the first half of 2018, and CEE markets recorded the highest growth as they are progressively closing the digital maturity gap with the leading Western markets."
The Study incorporates data from the following online advertising formats:
Additional segmentations are:
The Study can be accessed here.
1 Paid-for-search
For more information, please contact:
Alison Fennah, IAB Europe (fennah@iabeurope.eu)
Marie-Clare Puffett, IAB Europe (puffett@iabeurope.eu)
IAB Europe is the leading European-level industry association for the digital 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 uptake of harmonised business practices that take account of changing user expectations and enable digital brand advertising to scale in Europe.
About the AdEx Benchmark study
The data has been compiled by IAB Europe based on information provided by the national IAB offices around Europe. It is then processed and analysed by IHS Markit. The data represents the first half of 2018 January - June.
About IHS Markit Technology, Media & Telecom’s Advertising Intelligence Service
IHS Markit Advertising Intelligence Service provides its clients with a holistic and global view of a rapidly evolving advertising and marketing landscape. Developed and maintained by a team of expert analysts, it offers accurate, continuously updated market data, forecasts and reports that give our clients deep perspective on a dynamic advertising market. As the only global product that offers the same detail and scope for both established and emerging media we provide a unique, independent and objective view.
About IHS Markit (www.ihsmarkit.com)
IHS Markit (Nasdaq: INFO) is a world leader in critical information, analytics and solutions for the major industries and markets that drive economies worldwide. The company delivers next-generation information, analytics and solutions to customers in business, finance and government, improving their operational efficiency and providing deep insights that lead to well-informed, confident decisions. IHS Markit has more than 50,000 key business and government customers, including 85 percent of the Fortune Global 500 and the world’s leading financial institutions. Headquartered in London, IHS Markit is committed to sustainable, profitable growth.
IHS Markit is a registered trademark of IHS Markit Ltd. All other company and product names may be trademarks of their respective owners © 2017 IHS Markit Ltd. All rights reserved.
Explanatory note on IAB Europe/IHS Markit AdEx Benchmark figures
Each national IAB in Europe runs its own annual online advertising spending study and the IAB Europe AdEx Benchmark figures are based on these studies. As the methodology of the studies varies country by country, IAB Europe and IHS Markit have defined methodology rules to represent the figures in such a way as to make them realistically comparable. This involves:
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.”
Media contacts:
______________________________________________________________________________
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.
by Lisa Kalyuzhny, Director Advertising Solutions, PubMatic
IAB Europe recently published its Attitudes to Programmatic Advertising 2018 survey findings. This wide-ranging research, now in its fourth year, garnered feedback from the key digital stakeholders – publishers, agencies and brands - across 31 markets – providing a wealth of insight.
Having participated in helping interpret the data and build out the key findings, three key themes were evident from the advertiser perspective, which are important for programmatic going forward:
Ad fraud, ad misplacement and opaque platforms are all leading advertisers to consider in-housing to deliver transparency, control and insight to deliver to their objectives.
The survey shows nearly 40% of advertisers claim they are driving trading in-house. While this sounds great in theory, it brings major challenges.
56% of advertises claim they don’t currently have an in-house strategy, with issues around recruiting people with the right skills as a key barrier. 58% of advertisers are also finding difficulties in training people, adding to the pressure on building out their in-house capability. These concerns are also cited as barriers to brands investing in programmatic.
When it comes to ‘in-housing’ different businesses have different interpretations of what it means. Does it mean taking everything in-house? Does it mean the brand owning the technology and the data but the agency doing the execution around the buying? Does it refer to just in-housing certain elements, such as the creative side?
In-housing is easier to talk about than implement. Full integration brings major technology considerations and there are a wealth of complexities to tackle when adopting this approach. Earlier this year Vodafone publicly announced its decision to bring digital media trading in-house, only to backtrack on this strategy, highlighting the difficulties for brands to adopt this approach.
PMPs appear to be an important deal type for advertisers but there are big opportunities for this to grow, especially in mobile and video. Only 19% of advertisers invested 41% or more of spend in PMPs for mobile, while for video this sank to just 13%. For agencies, 44% invested 41% or more in mobile PMPs, while for video this was 51%.
For agencies, these high figures are indicative of the need to ensure safe environments for their brand clients. Advertiser percentages may be lower as they may assume (and expect) that the channels being used to reach consumers should be safe, so PMPs may not be seen as a necessity.
It will be interesting to see if the recent news around bid caching and auction manipulation impacts brands and drives interest in PMP.
One area where PubMatic has seen a growth in PMPs is in mobile, especially in-app. There is huge growth as eyeballs move here and brands want to engage in those channels where consumers are increasingly spending time. However, they have concerns around fraud, with in-app being a very different environment to desktop and a host of challenges around control. PMPs help alleviate some of these issues. This development is something PubMatic identified in our last Quarterly Mobile Index research into in-app.
The research highlights the ongoing challenges around campaign measurement for advertisers and their focus on sales KPIs for evaluating programmatic success. This suggests that the brand-specific metrics important to advertisers are still not being adequately addressed in a digital environment: an environment that has traditionally been direct- response led.
For advertisers, sales KPIs are critical, followed by brand awareness and purchase intent and viewability. Agencies have aligned to the advertisers needs, with sales KPIs being the number one metric. However, targeting accuracy and reach & frequency are then their key concerns, the focus here being more on deliverability rather than effectiveness. There is an opportunity for agencies to align more with the brands. Going forward, brands are also looking at brand lift, something they have traditionally measured in other channels, as well as engagement.
While challenges remain around programmatic, the survey highlights its continued growth and history shows that the maturing digital industry will develop solutions to address these issues.
To download a copy of the Attitudes to Programmatic 2018 Report, please click here.
This study, which has been carried out annually by IAB Spain since 2002, has as its main objective to provide the digital advertising industry with a report on media buying trends and to give an
investment figure.
This study is carried out on the basis of data provided by media agencies. These data have been compiled following a strict confidentiality agreement signed by PwC with the participants of the study.
PwC aggregated the data provided by the study participants. This aggregated information has been provided to IAB for its treatment and analysis. It was made available here.
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 third 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.
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.
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.
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.
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.
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.
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).
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/
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.
