As the managing organisation of the Transparency & Consent Framework (TCF), IAB Europe constantly strives to protect the integrity of the Framework and ensure that organisations who have signed up to the TCF comply with their commitments under the Framework Policies.

IAB Europe has been operating a Consent Management Platform (CMP)  Compliance programme for CMPs registered for TCF since 2019. The CMP compliance programme comprises a pre-implementation validation stage and a post-implementation enforcement stage, which enables IAB Europe to monitor live CMP implementations for compliance with the TCF Policies. The CMP enforcement process can result in the suspension of the participating CMP from the Framework for non-resolved breaches of TCF Policies.

IAB Europe is now expanding the Compliance programme to Vendors registered for the TCF. The aim is to identify and enforce against instances of non-compliant Vendor implementations, which may reduce consumer protection, expose Publishers and Vendors to legal risks, and undermine the reputation of the TCF in the eyes of both regulators and users. 

Scope of the Vendor Compliance Programme

In this first iteration of the TCF Vendor Compliance Programme, IAB Europe will audit live installations of Vendor technologies as integrated on Publisher properties and focus on assessing compliance with the following TCF policies:

Chapter III 16 (1) “A Vendor must not store information or access information on a user’s device without consent, unless the law exempts such storage of information or accessing of information on a user’s device from an obligation to obtain consent.”

Chapter III 16 (2bis) “A Vendor shall indicate on the GVL the maximum duration of information stored on a user’s device, including whether such duration may be refreshed.” 

Chapter III 13 (6) “A Vendor must not create Signals where no CMP has communicated a Signal, and shall only transmit Signals communicated by a CMP or received from a Vendor who forwarded a Signal originating from a CMP without extension, modification, or supplementation, except as expressly allowed for in the Policies and/or Specifications.”

Chapter III 16 (17) “A Vendor must not transmit personal data to another Vendor unless the Framework’s Signals show that the receiving Vendor has a Legal Basis for the processing of the personal data. For the avoidance of doubt, a Vendor may in addition choose not to transmit any data to another Vendor for any reason”.

Chapter III 16 (20) “If a Vendor receives a user’s personal data without having a Legal Basis for the processing of that data, the Vendor must quickly cease processing the personal data and must not further transmit the personal data to any other party, even if that party has a Legal Basis for processing the personal data in question”.

Over time, IAB Europe will aim to expand its automated audit capabilities to enable it to carry out more comprehensive and efficient assessments of Vendor compliance. Needless to say that, while the policies above constitute the focus of this initial phase of the TCF Programme, IAB Europe will continue to monitor compliance with all TCF Policies and adopt enforcement measures where non-compliance is identified, in line with its prerogatives under the TCF Policies and Terms and Conditions.

Enforcement process

From the 1st of September 2021, the enforcement process will be as follows:

• IAB Europe will regularly monitor top websites in key markets.
• IAB Europe may also act on TCF community reports of non-compliance.
• Where a live Vendor installation is found to be in breach of the policies, the following process applies:
  • If this is the first, second or third time a breach has been identified, in each instance, the Vendor will be given 28 calendar days to remedy the issues. If, following the expiration of the 28 day period, the issues have not been resolved, the Vendor will be suspended from the Framework and removed from the Global Vendor List until all compliance failures have been remedied;
  • If this is the fourth time within a twelve-month period that a breach has been identified, the Vendor will be suspended from the Global Vendor List with immediate effect for a minimum of 14 days and until all compliance failures have been remedied.

What is the TCF?

The IAB Europe Transparency and Consent Framework (TCF) was created to help companies that serve, measure and manage digital and personalised advertising content comply with certain obligations of the European General Data Protection Regulation (GDPR) and ePrivacy Directive (ePD) when processing personal data or accessing and/or storing information on a user’s device. It consists of Technical Specifications and Policies that assist all companies in the digital advertising supply chain to meet transparency and user choice requirements. 

The TCF enables publishers, through the means of a CMP, to inform and allow their users to exercise their choices on data processing pursued by them and/or the technology providers operating on their services (vendors). User choices are then recorded by the CMP in the form of signals (TC strings) to be transmitted and respected by the latter.

To ensure all parties can rely confidently on TC strings to determine their ability to process data, the TCF policies and technical specifications layout specific obligations and provisions for each category of participants (publishers, vendors and CMPs). IAB Europe supports participants in the application of their respective requirements through its compliance programmes.

For more information on the TCF or should you have any further questions on the TCF Vendor Compliance Programme, please do not hesitate to contact us at: communication@iabeurope.eu

On September 7 & 8, major brands and representatives from the digital economy will come together at Europe’s leading digital marketing & tech event! 400+ speakers will be taking the DMEXCO community on a journey into the digital future across 11 simultaneous streams. 

IAB Europe is proud to be one such representative, as we host not one but two key presentations and panels. Join us and our panel of industry-leading experts on 7th September as we dive into the Digital Services Act (DSA) and whether a ban on targeted advertising is on the horizon, and also share the results of our latest Attitudes to Programmatic Advertising Survey.

10:20 - 10:40 CET - Is the EU About to Ban Targeted Advertising? - Find out more and register here!

16:00 - 16:20 CET - Programmatic Advertising in Europe: Latest Trends, Attitudes and Growth Drivers - Find out more and register here!

Check out the full agenda here. 

#SettingNewPriorities: Industry-leading talks and premium networking opportunities 

Network live with experts and industry leaders. Actively participate in masterclasses, workshops, fireside chats, and keynotes – all from the comfort of your own home. Be inspired by the latest developments and ideas from industry leaders and global players, with talks from:

• Marc-Aurel Boersch & Laura Kiesewetter (Chief Executive Officer and Head of Digital Communications, Nestlé Deutschland AG), exploring the prerequisites for creativity and agility to guide international companies on the path to the future. 
• Stan Pavlovsky (CEO, Shutterstock), discussing new impetus in our changing society and the ability to set new priorities in a short space of time.
• Daisy Auger-Dominguez (Chief People Officer, VICE Media), addressing diversity, equity, and inclusion in the workplace, and examining the following: What impact have the measures taken so far had? What should/could be the next steps for decision-makers to drive progress forward?

Other confirmed speakers include Jen Fitzpatrick (Senior Vice President, Core at Google), Lindsay Nelson (Chief Brand and Experience Officer at Tripadvisor),

Timothy Young (President of Dropbox), plus many more big names and brands will be joining to deliver over 160 hours of premium content on an international scale. 

Unlimited access to all content for the rest of 2021

Did you know the standard ticket also grants you free access to all the sessions through to December 31, 2021, via the video-on-demand library? You’ll also be able to use all the features of the omnichannel platform, continue to conveniently arrange appointments, and make new contacts up until the end of the year.  

Visitors with a Premium ticket will be able to enjoy these services for an entire year! Plus you can secure a 20% discount on DMEXCO 2022, which will take place as a hybrid expo & conference. 

Get your ticket and become part of the international DMEXCO community. 

In this week’s member-guest post, we hear from Igor Gubin, Region Manager, Europe at Admitad Affiliate Network, as he shares his ideas on the measures e-commerce professionals should take to comply with privacy regulations and what needs to happen once cookies are dropped. 

In the last few years, consumer data has enjoyed raging interest from both businesses and governments. The policy for collecting, storing, and analysing data for marketing has become tougher, and — even though not completely aligned among the parties — now holds all of them accountable. Very soon, we will have to confront ePrivacy regulation, a brand-new set of rules to make daily routine harder for anyone promoting and selling digitally.

Tracking user activity still remains crucial for advertisers, publishers, online entrepreneurs, and other marketers. Without it, running a data-driven business in online sales and traffic monetisation is next to impossible. Surely, such monitoring has to be fully compliant with every legislation. Nobody likes to get fined.

Though GDPR and ePrivacy are broadly discussed, only a few know — and even fewer can tell — what to do. What measures should e-commerce professionals take to comply? What are we going to do once cookie dropping and storage get regulated beyond recognition? I would be happy to share a few ideas. But before I do that, here are some alarming statistics.  

State of affairs

London Economy researchers believe that after e-Privacy regulation (EPR) is adopted, European entrepreneurs may lose up to 30% of their income, and non-compliance fines will amount up to 4% of the companies’ annual revenue. No surprise that business owners are not particularly happy with the prospect. This is why implementation is taking so long — to date, the estimated time of the regulation’s arrival is around 2022.

Major companies are also concerned about data security and try to keep up with the shifting laws. Google, for instance, announced the company’s intention to get rid of third-party cookies in Chrome by 2023. This means marketers will no longer be able to collect user data as easily as before. Consequently, it will be more difficult to segment the audiences and personalise ads.

However, Google states that it’s going to assist marketers. The company is working on some new APIs that will help optimise advertising campaigns in a new way. Those are compound techniques, but should you find yourself deeply interested, you can read about them here. One of them is FLoC, the technology that some experts believe will ensure as accurate targeting performance as cookies do. 

(Meanwhile, other popular browsers — Firefox and Safari — have stopped using third-party cookies to track user activity long ago.)

Apple doesn’t trail along and has already announced changes in the new respective versions of the iOS and macOS, as well as dropping the IDFA (Identificator For Advertisers). All this will also affect digital marketing.

How to handle the GDPR?

But let us go back to GDPR. Don’t be confused with this seemingly intricate acronym. The regulation is very straightforward at its core and not to be disregarded.

Collect data properly, i.e., warn users that you are doing that. They have to give you a clear confirmation (by checking a box, clicking “OK” in the notification, or otherwise) that they have read and agreed to your policy of data collection and processing.  

Do not “pre-check” the consent box: the user must do it on their own. 

Here’s what it may look like:

Source: Formstack

We at Admitad Affiliate recommend using double opt-in, just in case. Double opt-in is a two-stage confirmation of a user’s intention to interact with you. For instance, after a user subscribes to your email newsletter in a special form (like in the image above), you send them another message with a request to give their consent once again. By doing this, you guard yourself against any claims or proceedings.

Register and keep the user’s consent in any form 

Now, let’s talk about storing data. In a perfect case, you need to have a procedure governing how you store user data, defining how you prevent unauthorised access to personal data. In your Privacy Policy, stipulate who can access the data in question and what you do to keep them secure. Those are technically sophisticated solutions, so you may want to seek help from competent people and trusted software. For example, select a paid cloud storage or google some “turnkey data storage solutions.” 

You need to introduce a user to the data collection, protection, and storage mechanisms that you employ. The Privacy Policy must be accessible for all visitors to your website. Abidance by these rules will make your subscriber base more specific and bring more trust to your relations. Down the road, you will have no regulation-related worries. 

However, you won’t be able to make do with these measures only once the EPR comes into full effect.

How to handle the ePrivacy Regulation

Everyone engaged in selling and promoting products and services online is going to face some problems associated with the implementation of the ePrivacy Regulation. To extinguish your early panic, we want to assure you that there are some solutions that will still be able to manage user data and use them for marketing purposes. 

One of the most straightforward solutions is first-party data or first-party cookies. That is data that a marketer, advertiser, or publisher has collected during a user’s direct interaction with, say, a website. Such data may be collected when a user leaves reviews or makes purchases. Those are data from CRM systems, subscription forms, and social media profiles—in one word, information a user voluntarily provides.

You as a marketer can collect first-party data on your own, without relying on third parties, in compliance with the GDPR.

Users’ identification 

First-party cookies are collected by deploying a pixel on the publisher’s website; such a pixel collects and records information about audience behavior. Such data can be collected every time a user visits the website or clicks on its link, views products, or fills out a form.

Another option is fingerprinting, a technology that helps create a probability identifier. It blends together a series of signals that help define a unique user and assign them a hashed identifier. Such signals can be devices, operating systems, browsers, IP addresses, time zones, and language settings.

Contextual marketing

Contextual advertising does not exploit any kinds of cookies. Instead, it uses keywords and phrases on a web page—avoiding any dependence on user data. According to a GumGum report, relevant ads ensure 43% higher engagement. Data suggest that clients do remember contextual ads 2.2 times better than other types of ads.

Chrome can track a user’s behavioural patterns when viewing web pages and then “put” the user in an audience, or “cohort” as they put it, based on such habits. As a result, advertisers will target cohorts rather than particular personalities.

Another solution that may help cope with the EPR restrictions is Soft Opt-in. For instance, you have a base of users who gave their consent to receiving commercial and marketing offerings from you. They are already your clients, and they interact with you. 

Once the ePrivacy Regulation comes into effect, you will not have to request their consent to interaction one more time. You will just have to send such users a notification informing them that they continue to cooperate with you and, thus, receive from you marketing messages relevant to the data you have already collected. 

Lawyers define such a method of dealing with the EPR as “probable.” But we can finally see whether it works when all the EPR provisions are fully firmed up and approved, given that they do not forbid Soft Opt-In in the first place.

No need to hit the panic button. And remember that some users will still accept cookies and allow marketing interaction. You can increase the share of such loyal users: for that, prepare a proper privacy policy and tell your users why you need their cookies, why it is important to your company, and why it is important to them. 

Here’s a great popup on Evian’s website that transparently explains to a visitor that cookies are collected for the purposes of analytics, personalisation of offerings, and showing relevant ads and information:

Building trust-based relations with users is the evergreen marketing strategy. When people realise that you treat their data with care, they are ready to provide you with all the necessary details. But don’t abuse user loyalty—and only collect data you really need. 

Moreover, software vendors will develop new solutions that will help identify and segment users without cookies. We at Admitad are already working on this. Stay tuned! 

IAB Europe has, not one, but two exciting new roles available to join our team! So, if you or someone you know has a keen interest in the world of digital advertising, are looking for a new challenge, and want to get involved with and contribute to the leading European-level association for the digital marketing and advertising ecosystem, then why not check out the job descriptions below and apply today.

Marketing & Industry Programmes Coordinator

Do you have 1-2 years of B2B marketing experience and a love for the digital advertising and marketing industry? Then this new role could be for you! Reporting to the Marketing & Industry Programmes Director this role will be responsible for assisting IAB Europe’s marketing department in coordinating all of its marketing efforts to members and the wider digital advertising and marketing community.

Check out the full job description and discover how to apply here.

Digital Advertising Analyst 

This newly created role is a unique opportunity to contribute to cutting-edge research and analysis on the digital advertising market and its intersection with technology, economy, and policy. Reporting to our Chief Economist, the Analyst will support a wide-ranging research agenda through data collection, modelling, analysis, expert liaison and deliver insights through contribution to written reports and presentations. 

Find out more and apply here.

In our latest network guest blog post, Jules Kendrick, MD, UK & Europe for the Trust Accountability Group (TAG) discusses TAG's new study on invalid traffic in Europe and how you can keep ad fraud low. 

For much of the past two decades, digital ad fraud has been a mysterious and malicious force, costing billions, whilst remaining largely unmeasured, unmanageable, and with little understanding of the challenge to be faced.

Several years ago, the Trustworthy Accountability Group (TAG) began to pull back the curtain on ad fraud through a series of studies in the United States, Europe, and the Asia-Pacific region to evaluate the effectiveness of its TAG Certified Against Fraud Program in reducing the rate of invalid traffic (IVT) and fraud.

Last month, TAG released its third annual benchmark study of ad fraud in Europe, which highlighted several learnings from its work across the continent, as well as a next-step strategy for companies to keep fraud rates transparent, manageable, and low.

The State of Ad Fraud in Europe
The TAG study showed very low rates of fraud across Europe, only when companies used channels in which multiple supply chain participants all adopted the same high anti-fraud standards.

Specifically, the study quantified an IVT rate of just 0.69% across TAG Certified Channels in Europe, a non-material change from the minimal 0.53% IVT rate measured in both 2019 and 2020. (TAG Certified Channels are channels in which multiple entities involved in each ad transaction – such as the media agency, buy-side platform, sell-side platform, and publisher – have all earned the TAG Certified Against Fraud Seal.)

By contrast, the rate of IVT was more than three times higher when companies used a channel in which only a single entity had obtained TAG certification. Put simply, when you triple filter inventory across the digital supply chain, fraud rates are three times lower than just employing your own anti-fraud vendor.

The ability of companies to maintain such a low IVT rate over time is particularly notable given the significant increase in ad fraud attacks during the pandemic, as criminals attempted to profit from the confusion and dislocation of those events.

That increase in criminal activity was blocked by the interlocking protections built into the supply chain when multiple companies required their partners to set the same high standards they had adopted against fraud.

Why Measurement Matters
The study was conducted by The 614 Group study and evaluated IVT rates in TAG Certified Channels by measuring more than 117 billion ad impressions. The data was captured from January-December 2020 from three of the largest advertising agency holding companies across the 5 largest European markets; the United Kingdom, Germany, France, Italy, and the Netherlands.

Commenting on the study, Rob Rasko, CEO of The 614 Group, highlighted the importance of continuous analysis around complicated challenges like fraud. “Accurate and consistent measurement is critical during times of turbulence, when sudden supply chain dislocations are common and dramatic shifts can occur,” said Rasko. “This benchmark measurement has now proven itself over the past three years as the single most important metric for the effectiveness of anti-fraud programs in Europe."

In addition to the quantitative results, the study also conducted a qualitative analysis through interviews with senior executives from the participating ad tech holding companies. Those experts ascribed the significant increase in attacks through mobile channels to changing consumer behaviour and the impact of the pandemic. They affirmed that benchmarks to measure fraud over time are critical to industry analysis of the problem. The experts also noted that many agencies are now requiring their publisher partners to obtain TAG certifications.

Lessons for Other Regions
While the European study didn’t explicitly focus on other regions, TAG has now conducted similar research across four continents, all of which points to the same conclusion: Successfully fighting fraud requires cross-industry collaboration to set consistently high standards across all participants in the supply chain. In regions with less developed digital advertising markets, the baseline rate of IVT and fraud may be higher, but the solution path is the same. In those emerging markets, however, the tools and resources provided to industry participants are critical to helping them understand the importance of this common standard-setting process.

Learn More About the Study and TAG Certification
The full 2021 study can be found here. Additional information about TAG’s Certified Against Fraud Program and how companies from across the advertising ecosystem can receive the TAG Certified Against Fraud Seal can be found here.

Brand Suitability describes the practices and tools that are put in place in addition to brand safety controls to ensure that a digital advertising campaign appears against content that is deemed relevant and appropriate for the brand. It equally refers to the ability of a brand to choose the risk profile suitable to their brand - low, medium, or high risk. The scale was, as well, developed by the 4As and endorsed by GARM.

Eighty-two percent of marketers say appearing next to unsuitable content impacts a brand’s reputation, and one in four brands and agencies have experienced negative press due to brand suitability incidents, according to eMarketer. Brand suitability is, therefore, the answer to many of today’s toughest brand stewardship questions. Where traditional brand safety tools relied on cookie-cutter approaches to avoid unsafe or inappropriate content, brand suitability is more nuanced and attuned to individual brand risk sensitivities. It helps to identify the advertising environments that will help digital campaigns drive outcomes for the business and uses individual brand profiles, market research insights, and strategic positioning to find and target specific environments for advertising, using a customised approach. 

Nevertheless, we should not forget that while suitability is the new game in town, brand safety is an absolute basis which we should all be upholding day in, day out. Brand safety should be applied to every digital advertising campaign. Brand suitability is an important, additional layer.

So how does brand suitability work for programmatic campaigns? We asked members of IAB Europe’s Programmatic Trading Committee to share their experiences.

Q&A with Nick Welch, Programmatic Director Northern Europe, Integral Ad Science (IAS), and Tanisha Sakhawat, Senior Business Director, EMEA, DoubleVerify from the Programmatic Trading Committee.

Q1. What is the first step in applying brand suitability to a programmatic campaign?

“First and foremost, it’s important to understand the brand's appetite to risk in relation to the context in which their ads are seen. Having established this, it’s then important to take a multilayered approach defining the brand’s tolerances at a topical, vertical and then at a brand/product or a services level.” Nick Welch, IAS

“Align your brand safety and brand suitability pre-bid settings with your post bid settings. This will help the buyer avoid unnecessary media wastage and enable the campaign to scale across authenticated quality media. Many may think, “Why do I need both pre-bid and post-bid brand safety and suitability on my activity?” And it is a good question. 

We liken it to a ‘seat-belt and airbag' relationship with the pre-bid brand safety controls being the seatbelt — something that is always on and keeping the campaign safe — and the post-bid controls, which use blocking or filtering technology, are there just in case the pre-bid setting does not identify an unwanted impression.” Tanisha Sakhawat, DoubleVerify 

Q2. What are the benefits of adding brand suitability to brand safety parameters?

“Brands invest a significant amount of time creating an image, cultivating consumer perception, and fostering long-term associations. Therefore, it’s important to ensure digital messages appear in safe and suitable environments. Not solely to avoid risk, but also to effectively reach the right consumers. All brands are unique and their definition of safety and suitability is driven by their own values and goals. 

Brand suitability is able to offer a more nuanced control of the context the brand may choose to appear against or avoid. With brand suitability, advertisers are able to address any topical or vertical-specific concerns. Additionally, the benefits of adding on brand suitability means that brands can avoid content specifically negative about their brand. 

Brands are consistently having to navigate social issues or global events such as the Euros or Olympics. In such instances, if a brand wants to avoid running ads beside certain contexts that may reflect negatively on the brand, a keyword-only or brand safety approach would not achieve this. It is only by applying robust technology that can execute brand suitability well that such content can be targeted or avoided. 

Not having the right parameters in place can have a huge impact on both the bottom line and the brand reputation in the eyes of the consumers.” Nick Welch, IAS

“Brand safety has a more universal floor that is widely adopted by brands and advertisers. Content like graphic photos or terrorism, for example, is seen as unsafe for almost any brand. But brand suitability is different; each brand will have its own specific brand suitability preferences and brand values to uphold. In other words, what may be suitable for one brand may not be suitable for another. 

Consider an article about finding cheap alcohol delivery. This most likely would not be suitable for a brand that maintains a family-friendly image. But a company such as Samsung may serve ads alongside such content because:

• Their brand preferences allow for this type of alcohol-related content.
• Their target audience may be reading it.

Brand suitability requires a more nuanced approach that enables brands to build suitability that fits their specific brand preferences. 

Understanding the article is about alcohol gives us context, but the type of article it is gives us more. For example:

• User-generated content around alcohol drinking has much higher risk because of the unmoderated and unedited nature of that content. 
• News articles around alcohol drinking give us less risk due to its editorial standards – but still may be inappropriate for certain brands. 
• Educational content around avoiding binge drinking or drunk driving is more palatable to a wider range of brands.” Tanisha Sakhawat, DoubleVerify

Q3. How does pre-filtering work? And what are the best practices?

“For programmatic buys, using pre-bid filters ensures that brands only pay for quality impressions that are suitable. Buyers then do not bid on impressions that will be wasted due to brand safety concerns. When pre-bid filters are applied, analysis occurs in the DSP ahead of the bid and prevents brands from buying on unsuitable impressions. Finally, pre-bid filters allow savings on media costs and data fees associated with those unsuitable impressions.

In terms of best practices, ensure that programmatic buys are protected with pre-bid brand suitability segments applied, to avoid appearing adjacent to risky content. Check that the content verification providers’ pre-bid targeting segments are integrated within all major Demand Side Platforms (DSP), allowing brands to target only safe impressions before ever placing a bid. 

When setting up brand suitability at the pre-bid level, ensure you have a good understanding of your risk tolerance across all levels; standard brand safety, topical, vertical, and brand-specific avoidance. Migrate away from using keyword-only approaches and use semantic solutions capable of accurately understanding the context as close to human beings as possible, and are able to determine the sentiment and emotion of the content.” Nick Welch, IAS

“Pre-bid avoidance tools (aka pre-filtering) sit within the DSP and tend to be powered by data provided through third-party partnerships between verification vendors and the DSP. It’s important to note that this is not referring to any kind of cookie or audience data. The data here is about content. These tools in the DSP allow third-party verification providers to determine whether or not to bid on a programmatic impression based on impression-level data it receives from the auction that meets the advertiser’s own brand safety and suitability settings, and in many cases is fraud-free. By knowing if an impression is fraudulent or will be shown outside of an advertiser’s brand safety requirements before it’s purchased, a brand can avoid purchasing it altogether — reducing wasted media spend and improving post-bid block rates. 

Again, aligning brand safety and brand suitability pre-bid settings with post bid settings will help the buyer avoid unnecessary media wastage and enable the campaign to scale across authenticated quality media.” Tanisha Sakhawat, DoubleVerify

Q4. What are the main considerations for applying brand suitability to programmatic campaigns?

"Determine brand value and campaign goals

Determine the risk tolerance and set brand suitability settings, balancing this with campaign goals. 

Choose the right partners

Work with global digital verification partners that are integrated with all the major DSPs. Also partners with solutions that comprehend context fully using natural language processing and can deliver accurate sentiment and emotion analysis.

Reduce the reliance on keyword-only strategies

Migrate away from keyword-only strategies, both with the content verification provider and with the DSP. Rely on contextual segments in their place. Apply this approach at a post and pre-bid level in order to ensure brand suitability whilst minimising wasted budget on low-quality impressions.

Consider buying models and apply the same pre-bid filter against both OMP and PMP buys

Private marketplaces (PMP) are a great opportunity once key partners have been established. However, it is crucial that advertisers don’t lose sight of their brand suitability goals and ensure the quality of the media being passed via these curated marketplaces or PMPs meets their requirements for brand safety and suitability.” Nick Welch, IAS

“By knowing if an impression is fraudulent or will be outside of an advertiser’s brand suitability requirements before it’s purchased, a brand can avoid purchasing it altogether — reducing wasted media spend and improving post-bid block rates.” Tanisha Sakhawat, DoubleVerify 

Q5. What are the technical challenges? 

“One of the challenges is bid stream transparency, as not all supply is fully transparent. On occasions, the SSP (Supply Side Platform)/ DSP or Publisher masks the URL, which means that content verification partners are prevented from seeing the actual URL at the pre-bid level. Typically, at the point of delivery, i.e. after the bid is won, the destination URL may be exposed, so a verification partner can still perform its role and determine if the context is suitable or not and take the correct action.

Secondly, with a greater emphasis on transparency in the media buying process, it’s important to mirror pre-bid brand suitability settings at a post-bid level too. If post-bid tags are enabled, brands can access programmatic reporting to get access to verification metrics at the DSP, line item, exchange level, and deal ID levels in order to effectively optimise supply paths.

Finally, it’s important that brands apply post-bid brand suitability filters where supply has passed via curated marketplaces or PMPs to ensure the quality of the media meets the advertiser’s brand suitability requirements.” Nick Welch, IAS

“In many native app environments, such as mobile app and CTV apps, brand safety and suitability can only be delivered at the app level, taking into account app store category, store rating, and age rating. More granular controls are being developed by some vendors to offer content level transparency to customers.” Tanisha Sakhawat, DoubleVerify

Q6. What type of KPIs do you see with brand suitability being applied to programmatic campaigns?

“There are a number of campaign measurement parameters that brands should have in place when assessing programmatic campaigns. Some of these are a prerequisite despite the media buying method:

• Identifying reduced block rate in post-bid reporting 
• Reducing media cost, data cost and ad serving costs associated with wasted impressions
• Diverting budget to more suitable content, minimising reputational and financial cost of advertising in inappropriate environments” Nick Welch, IAS

“KPIs will usually be reach and scale while targeting the right audience in the best environments. A significant reduction in post-bid blocks or incidents will be seen when applying brand suitability to programmatic campaigns, meaning brand equity is being protected.” Tanisha Sakhawat, DoubleVerify

Q7. What are the must-ask questions when conducting a programmatic campaign with brand suitability? 

“There are many questions a brand should consider when conducting a programmatic campaign:

• Are brands working with a content verification partner that uses natural language processing to understand page-level semantics, sentiment, and emotion in real-time? Is their solution and technology scalable, and able to work with billions of impressions across all the leading DSPs?
• Has the brand migrated away from a keyword-only approach, both with their content verification provider and the DSP’s own verification settings?
• Have they applied the same strategy on the pre and post-bid level for optimal results and efficiency?
• Have they applied the same brand suitability principles against their PMP deals as well as at the Open Marketplace (OMP) level?” Nick Welch, IAS

“A key question to ask is ‘who is the target audience’? For example, you may want to target females for a new alcohol brand launch, but avoid pregnancy content that females will be reading. Pregnancy content wouldn’t traditionally be seen as ‘unsafe’, but it is not suitable for an alcohol brand to be aligned with. Another question to raise is ‘what is the brand’s stance on diversity, equity and inclusion'? Often, keywords are added to lists that exclude important audiences, for the wrong reasons. Revisiting the technology used behind blocking certain themes is paramount when it comes to brand suitability, so asking what methodology is being used is important (a deterministic methodology is key!).” Tanisha Sakhawat, DoubleVerify

Q8. Any examples of how brand suitability has advanced the targeting and outcomes of a programmatic campaign?

“Brand suitability has most certainly advanced and become much more nuanced. For example, when the global pandemic hit in 2020, Vodafone Italia found that their campaigns were not scaling as well as they had previously. This was primarily because their brand safety settings were being triggered too aggressively as content related to the pandemic — both positive and negative — dominated the news. DV worked closely with them to help develop an enhanced brand safety and suitability strategy for their campaigns — enabling them to strike a better balance between protection and reach.

By quickly reacting to higher block rates, Vodafone Italia saw a significant increase in campaign scale. Daily blocked impressions immediately declined by 49% and quickly returned to Vodafone’s Block Rate benchmark. Also, campaign performance increased materially in the week after implementing solutions — seeing increased sales and a 26% reduction in CPA.” Tanisha Sakhawat, DoubleVerify 

Q9. Finally, what’s the future of brand suitability?

“As audiences continue to flock to CTV, advertiser demand for transparency in CTV is accelerating. When it comes to brand suitability, advertisers should ensure they can safeguard their investments from unsuitable environments through measurement and protection controls at content category level — such as Crime, Violence, Copyright Infringement, Inflammatory News and Politics, and many more. 

Advertisers will also want to partner with verification companies that allow them to monitor and optimise away from unsuitable CTV apps based on user age ratings, star ratings and app store categories like ‘Kids and Family’ or ‘Adult.’  

With continued innovations in CTV measurement and controls, advertisers can exercise more refined and nuanced avoidance strategies catered to the brand while preserving campaign scale.” Tanisha Sakhawat, DoubleVerify 

Thanks to the committee for their views on how brand suitability works in the programmatic environment. As well as IAB Europe, there are already a number of business groups actively contributing to the Brand Safety & Brand Suitability conversation:

• Trustworthy Accountability Group: TAG is the leading global certification program fighting criminal activity in order to increase trust in digital advertising. TAG recently acquired JICWEBS, which has a brand safety certification program. 
• The 4A’s Advertiser Protection Bureau (APB) is a group formed to enable agencies to share the collective responsibility of achieving Advertising Assurance, which is how the association defines its efforts to create environments where brands and consumers can coexist with trust. 
• The World Federation of Advertisers (WFA)’s Global Alliance for Responsible Media (GARM) initiative: This collective brings together advertisers, agencies, media companies, platforms, and industry organizations to improve digital safety. 
• Media Ratings Council (MRC) has a number of auditing programs for measurement as well as for brand safety. 
• IAB Tech Lab focuses on ad tech standards, including those intended to support brand safety capabilities in a consistent and common manner; Tech Lab partners with other industry organizations to enable their efforts in standards.

In this week's member-guest post, we spoke with Nick Morely, EMEA Managing Director at IAS on Integral Ad Science’s (IAS) latest report, Pandemic Effects: What’s Next in Shifting Consumer Priorities, which highlights how UK consumer habits have changed over the past 18 months. He explores consumer priorities post lockdown and shares how advertisers should take note. 

Nick Morley leads the strategic development of the EMEA business at IAS, a global leader in digital media quality. He has a proven track record in launching and scaling high-growth businesses across Europe, with a decade’s worth of digital advertising industry experience. 

No one can deny that it’s been a transformative 18 months, both for consumers and the digital advertising industry. Consumers have shifted their focus toward digital and the advertising industry has adapted towards an ever-changing landscape. But what consumer habits are likely to stay and how can advertisers continue to build meaningful connections with consumers in a post-pandemic future? These are some of the questions answered in IAS’s latest report, Pandemic Effects: What’s Next in Shifting Consumer Priorities.

New UK habits as restrictions ease

Knowing the preferred activities of consumers and their plans for spending in the coming months gives brands and agencies the ability to optimise their digital campaigns. What’s more, the importance of digital advertising in the shopping experience cannot be ignored. 

The majority (92%) of UK consumers plan to continue at least one habit formed during lockdown periods after restrictions have been lifted, the study found. In fact, almost half (49%) of consumers will continue online shopping, and more than four in ten (45%) will continue using contactless payment methods. 

Despite the majority (68%) of Brits looking forward to resuming social activities as restrictions ease, two in five (40%) remain concerned over confusing or conflicting guidelines for social gatherings and more than one in ten (15%) will not engage in social activities as COVID-19 restrictions are lifted. 

UK consumers have saved and are keen on spending

As the vast majority of restrictions are lifted in the UK, it’s clear that habits established during recent national lockdowns will have a lasting impact on consumers’ social and shopping activities post-pandemic.

Consumers are keen on spending as establishments open up, with over a quarter (27%) reporting more savings since lockdown, and over a third (38%) anticipating that their spending will increase in the next year. 

Retail purchases post-pandemic will be split equally between physical stores and online channels for half (51%) of consumers. Additionally, six in ten (60%) of shoppers confirmed that they will make a conscious effort to support small and local businesses.

As local restrictions are easing, people everywhere are debating what the ‘new normal’ will look like. With the majority of UK consumers looking for a hybrid shopping experience as further restrictions are lifted, brands are presented with an opportunity to align their online and offline strategies to ensure that they’re reaching reinvigorated shoppers. 

Safe and reputable sites remain key

More than half (54%) of consumers believe that online advertising will play an important role in helping them find information on the products and services available to them post-pandemic. To source this information, almost half (45%) will use search engines, while more than a third (37%) will use social media sites and apps. 

Looking ahead, one in two (51%) Brits believe that online advertisements that appear on safe and reputable sites are important. In addition, almost half (49%) of consumers want ads to be relevant to the content that they are consuming, and a similar amount of consumers (47%) want this content to heavily feature a promotional or discount message. 

Furthermore, almost half (44%) of consumers believe that online advertisements should highlight a brand’s commitment to certain social issues and advocacy, while two in five (40%) want ads to recommend products and promotions based on what they have previously purchased.

For brands, it’s clear that this is an opportunity to prioritise digital channels, while ensuring safe, suitable, and contextually relevant ads that build brand preference and long-term customer relationships.

Media outlook 

As we look ahead, it’s important to understand how media quality is impacted by global events and technological shifts around the world. Alongside consumer priorities, we also know that UK brand risk increased across all media environments in H2 2020, driven by political and societal movements during an unprecedented year. 

Our studies show that safe, suitable, and contextually relevant advertising will be important to engage and build preference among these consumers. Ad environments must be considered from both a contextual and sentiment perspective to drive a much-needed boost in post-pandemic retail revenues and capture consumer interest.

As we consider what the world could look like after the pandemic, one thing is certain: many of the newly formed consumer habits will continue to change and evolve. To find out more about how the industry can utilise these insights to drive better media outcomes, visit here.

Authored by Industry Leaders from Across Europe

Provides Valuable Insights, Key Considerations and Best Practices for Contextual Advertising

28th July, Brussels, Belgium:  IAB Europe, the leading European-level industry association for the digital advertising and marketing ecosystem, has today released its ‘Guide to Contextual Advertising’ to provide further education on alternatives to third-party cookies and to help planners and buyers of media navigate this solution. 

This guide has been developed by experts from IAB Europe’s Programmatic Trading Committee. It offers a definitive round-up of what contextual advertising is, and the opportunities it provides in Europe, particularly in a post-third party cookie world. It also offers key considerations and best practices. In doing so, it ensures that buyers of media have the necessary tools and knowledge to implement effective contextual advertising campaigns.

Contextual advertising has always been a fundamental part of the marketing mix, but advancements in technology and a shift towards privacy-focused solutions, accelerated by the end of third-party cookies, have brought contextual advertising back into focus. Commenting on the role that contextual advertising plays in the digital ecosystem today, David Goddard, Chair of IAB Europe’s Programmatic Trading Committee & Senior Director, Business Development at DoubleVerify said “With the demise of cookies, marketers are seeking new ways to optimise campaign performance and to ensure the efficiency and effectiveness of their ad campaigns, as well as creating more meaningful consumer experiences. In today’s privacy-first ecosystem, contextual advertising is one privacy-safe solution that works. The guide, written by experts from across the advertising ecosystem, highlights the evolution of, and opportunity for, contextual advertising perfectly and provides best practices for applying this strategy as we move into a post third-party cookie world. We encourage all industry stakeholders to read this guide to help maximise the potential that contextual advertising brings.”

It has been a collaborative effort to produce this European-level industry guide for contextual advertising, with contributors including Bloomberg Media, CNN International, Comscore, DoubleVerify, IAS, Magnite, PubMatic, Rakuten Advertising, Triton Digital, and Xandr. 

Commenting on the value of the Guide to Contextual Advertising, Nick Welch, Programmatic Director, Northern Europe, IAS  said "All eyes are on contextual targeting as the industry continues to phase out from third-party cookies. Data and sophisticated technology are coming together to enable marketers to move in the right direction with precision and at scale. As digital media quality continues to evolve and we navigate through the latest industry regulations, IAB Europe's Industry Guide to Contextual Advertising is beneficial to understand the latest developments in contextual targeting opportunities. IAS is excited to have contributed to the guide, which covers important components including a step-by-step guide to planning contextual campaigns and emerging digital channels such as CTV."

"Against the backdrop of a cookieless world, contextual advertising is more important than ever,” Simon Baker, Head of Programmatic EMEA at Bloomberg Media said. “This seismic shift in the industry presents an opportunity for premium publishers to leverage their unrivaled access to audience insights in order to better serve client needs and objectives.”

Rachel Gantz, General Manager, Activation Solutions at Comscore also said “Comscore has long supported clients with GDPR friendly contextually driven targets. We are delighted to have contributed to the latest guide from IAB Europe to share our experience and highlight the vital importance of contextual advertising for the future of our industry.”

This guide is a key output for IAB Europe’s Programmatic Trading Committee this year and follows the updated ‘Guide to Post Third-Party Cookie Era’, which was released in February 2021. The committee aims to increase understanding of the programmatic ecosystem and the impact it’s having on digital advertising and to influence industry initiatives to improve the ecosystem. Digital advertising in a post third-party cookie world is a key area of focus and industry topic for the committee in 2021. 

For third-party cookie solutions such as contextual advertising to flourish, it is vital to work together as an industry to ascertain guidelines and best practices for each solution. Commenting on IAB Europe’s focus to raise awareness on such solutions, Helen Mussard, Chief Marketing Officer, IAB Europe said, “When we set out at the start of 2021, a main focus for the committee was to continue to educate the market and build confidence in digital advertising and marketing solutions that provide alternatives to third-party cookies. Being able to provide a forum for members to collaborate, and share best practices and advice in this area has never been more important for the future of our industry. The Guide to Contextual Advertising shows that by working together we can open up new opportunities and share greater ideas to ensure success.” 

IAB Europe is working with some of its members to provide additional insight into post third-party cookie solutions, including contextual advertising, through a series of webinars, guides, and working groups. These will continue to be expanded upon, alongside new initiatives, for the remainder of 2021 and into 2022.

The Guide to Contextual Advertising can be downloaded from IAB Europe’s website here. 

The European Connected TV (CTV) market has soared in recent years to become one of the hottest topics in our industry. Where the worlds of TV and digital have been gradually merging over time, more and more consumers have been tuning out of traditional Linear TV options and moving into online streaming, paving the way for the CTV phenomenon. In Europe, CTV presents a huge opportunity for advertisers to reach engaged audiences with the right message. But for the CTV market to reach its full potential in Europe scale is key, and for that to happen programmatic CTV needs to be adopted.

In this blog post, we caught up with some of the contributor’s to our Guide to the Programmatic CTV Opportunity in Europe and members of the Programmatic Trading Committee to find out what the status of programmatic trading for CTV across Europe is, what buying options are currently available, and what we need to do to scale CTV programmatically. 

What is the status of programmatic trading for CTV across Europe? How does this compare to other regions, like North America and APAC? 

“It’s a really exciting time for CTV in Europe. While it’s still relatively early days for the channel, we’re seeing a lot of developments on the broadcaster side and ever-growing numbers of brands and agencies incorporating it to supercharge their campaigns. 

North America is naturally further ahead but can provide a great snapshot of what’s to come. A major factor that’s impacted adoption in Europe is that linear TV has been so successful for the established broadcasters that they’ve been resistant to programmatic and the change that it brings. However, we’re really seeing the tide turning on this with many big players beginning to embrace digitalisation. 

We expect to see European broadcasters evolve their digital TV offering space in the coming months, aligning increasingly closely with other digital channels. Our recent research found that nearly one in five (19%) of Brits watch more than 16 hours of streaming a week - so it’s understandable broadcasters want to keep pace with consumer appetite. As this happens, advertisers will shift increasingly large proportions of budget to this channel.” Patrick Morrell, Director, Inventory Partnerships, The Trade Desk  

“According to our latest research, The Future of CTV advertising in Europe, there is a lack of unified definition across the region. During the research, we encountered not only a lack of consistency in what constitutes CTV across different markets, but we also found an array of definitions within markets. For some, it’s any TV connected to the internet. For others, it’s smart TVs, or even on-demand only. And in markets where HbbTV and IPTV are prevalent, there was no consensus on whether those technologies constituted “connected TV”. In one market HbbTV is regarded as connected TV, and in others it isn’t.

In our research, we found a two-speed Europe – large global players with unified content and tech infrastructure are moving relatively quickly, while local players, often with legacy TV businesses, are moving more slowly. Nevertheless, they are actively setting up OTT/CTV operations, though with diverse models and strategies, and in a more incremental fashion.” Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic   

What are the buying options available for CTV programmatically? How is it typically bought and through what deal type?

“All markets are available for CTV buying, but, across Europe, the majority of CTV inventory is bought through Private Marketplaces (PMPs). Broadcasters will typically go for Programmatic guaranteed with some 1-2-1 preferred deals, but this is changing, and more are opening up PMPs. OTT First publishers will tend to offer PMPs as their preferred route to market.”  Patrick Morrell, Director, Inventory Partnerships, The Trade Desk  

“With highly engaged, addressable audiences to reach on CTV, marketers should no longer be looking at programmatic as an afterthought, but as an essential part of their strategy to bring more efficiency and accountability into their media investments. Programmatic technology gives brands the dexterity they need in a changing marketplace. They can stop a campaign almost immediately and have a new one up and running within hours. 

Programmatic doesn’t just pertain to the open marketplace. It also means gaining access to private, premium marketplaces and environments that give buyers assurance that their campaigns are running where they want them to. In fact, the majority of CTV transactions occur within curated, private marketplaces, giving buyers greater control as to how they structure deals and more insight into how their ad dollars get spent.

Programmatic makes it much easier for buyers to manage all of their placements and vendors through a single source or deal ID.” Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic  

“The lack of both OpenRTB standards in the open marketplace and a reliable definition of OTT across ad tech platforms has combined with TV publishers’ desire to maintain control over their inventory to produce a closed, deals-based economy when it comes to OTT/CTV.

When it comes to OTT/CTV, deals serve as a proxy for the lack of tech and TV’s traditional direct buying process in three major ways: defining the inventory, providing control, and improving accountability/reporting.

OTT/CTV deals typically take three forms. Private Marketplaces (PMPs): a deals-based method for suppliers to offer ad inventory packages built around audience data, impression attributes, content type, etc., to a group of buyers pre-approved by the publisher. Preferred Deals / Direct Deals: 1:1 deals established between a publisher and a buyer for a fixed-price CPM. And Programmatic Guaranteed Deals: deals established between a publisher and a buyer for a fixed-price CPM that guarantees access (reserved traffic) to a minimum number of impressions for the buyer, and a minimum spend to the publisher.” Adam Noble, Product Marketing Director, Index Exchange

How can a buyer scale CTV programmatically? What types of clients are you seeing have the most success?

“It really depends on what they’re trying to achieve and what the goals of the campaign are. The beauty of CTV is that it offers flexibility and the ability to test so advertisers can really hone campaigns according to their objectives. For instance, if they’re simply trying to maximise reach, they should keep the target audience broad. But if they’re looking for something more response-led, then it makes sense to run a test to find out where their audience is geographically, and on which publishers. What many people don’t appreciate is that it's incredibly cost-effective to run tests, and it will help inform and optimise future campaigns. 

There’s no one type of client that CTV works better for - like any digital channel, it has universal benefits and appeal. The key is spending time getting to know how the channel works - with the help of partners - to ensure you’re making the most of it.” Patrick Morrell, Director, Inventory Partnerships, The Trade Desk  

“With programmatic buying, brands and agencies win access to addressable audiences at scale. For example, buyers can easily go to 30 premium CTV publishers at once, all with the ability to reach their target audience. This is a planning advantage so buyers do not have to buy from many publishers individually like they would have to in a non-programmatic environment.

Programmatic pipes put CTV inventory in one drive, and we’re seeing demand increase across the board. With programmatic’s targeting capabilites, advertisers of all sizes can deliver their messages for optimal impact to engaged viewers. Whether it’s a buyer from a major agency or a small DTC marketer, programmatic CTV opens up access to premium inventory, regardless of budget size. The attraction of the DTC brands or regional brands is something that many agencies are excited about.” Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic  

 “This depends heavily on the buyer type, audience criteria, and campaign goals. Large buyers will often broker direct deals with premium suppliers, such as broadcast and cable TV networks, as well as select digital pure-plays with scale and/or gated access to inventory, such as Hulu. In addition to direct deals, buyers of all sizes will tap into private marketplaces established by OTT/CTV SSPs for scale across the broader spectrum of OTT inventory that often includes a substantial portion of FAST and vMVPD supply. Such marketplaces typically take the form of general, run-of-network pools of OTT inventory accessed via a deal ID that is targeted by the buyer’s DSP. These marketplaces are also often verticalised according to the buyer needs, with separate deal IDs for CTV-only inventory, and/or deals based on price point, contextual category, audience segment, etc.

Clients with the most success tend to work across the spectrum of deal access, from direct negotiation with publishers to ensure baseline access to premium supply, and DSP activation of multiple SSP marketplaces to ensure scale for fulfillment and audience targeting.” Adam Noble, Product Marketing Director, Index Exchange

What are the typical targeting methods available and what do you recommend to partners?

“With any advertising activity, understanding the desired outcome is key. We work with our clients to understand what they are looking to achieve - which is often multiple elements, of varying priorities. Then, with the help of our platform, we use these goals as the starting point for the campaign plan. Our advanced AI technology is embedded across the platform and analyses millions of data points to help advertisers ensure their CTV buying is as optimal as possible. 

This process encompasses a number of different targeting options from demographic to geography to genre. We also work with partners such as Samsung TV Plus who offer data technology that captures everything happening on the glass and enables a more customised content discovery experience.

The key is to stay flexible. It can be tempting to get a fixed idea about the targeting method to pursue, but one of the benefits of CTV is the ability to evaluate performance and update accordingly - so we encourage advertisers to take advantage of that.” Patrick Morrell, Director, Inventory Partnerships, The Trade Desk

“This sounds obvious but the fact that we still tend to target individual users, rather than considering the context of the content, is something that needs to change. The media landscape has evolved, the technology has evolved, and the innovation in the space has really driven new opportunities to leverage the potential of contextual advertising. Thinking contextually creates a number of benefits. Firstly, it ensures accurate content classification, so the brand suitability and targeting are on-point. It's consumer privacy-friendly. It extends reach and allows you to target broader audiences while still allowing for a certain amount of precision in finding audiences at a certain point in their buying journey. Finally, it reduces ad fatigue. The viewer only sees the ad in the right context, so it doesn't feel as though the ad is following them around.”  Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic  

“OTT campaigns are often targeted according to basic demographic targets such as age and gender, zip-based location, and interest-based audience segments composed by data management platforms.

True addressability is limited for OTT campaigns given that Connected TVs are cookie-less devices often viewed by a household, rather than one specific individual. As a result, most OTT targeting is done according to HH file and IP address, which works well for targeting basic audience segments from DMPs, but are inadequate for accessing that next layer of targeting and insight, such as who, exactly, is in front of the TV right now. Authenticated audiences built upon publisher networks of first-party data allow SSPs to help increase match rates by enriching the audience signals sent to buyers, however, this data is often hard to scale without the help of identity and graph partnerships, and even then, is challenged by a dynamic of shared logins and inaccurate data associated with IPs and HH files. As a result, contextual signals are often defaulted to in order to help improve targeting for campaign relevancy.” Adam Noble, Product Marketing Director, Index Exchange

How do you measure the success of CTV campaigns? 

“Without wishing to sound like a broken record, it really depends what you’re looking to achieve. At The Trade Desk, we work with various partners that can offer our clients different measurement metrics, according to their goals. For example, for reach and frequency – we work with several measurement specialists that can measure the reach and frequency of your campaigns vs. linear and BVOD, clearly demonstrating the added benefits of including CTV. We also work with a specialist company to help track brand uplift. Patrick Morrell, Director, Inventory Partnerships, The Trade Desk

“Without a doubt, there needs to be a greater push in the industry around standards for measurement. As an industry, we need to agree on what to measure and how to measure across all platforms. This includes a common set of metrics to compare the performance of OTT to linear TV, especially around reach and frequency.  

At the moment we have lots of data sitting in silos, there needs to be a shared approach to measurement that is used consistently across all platforms and channels. This will require a lot of collaboration, which may be tough, but will really help OTT take off, and more importantly, provide advertisers with confidence in this new space.” Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic  

“A majority of OTT campaigns use basic delivery metrics to define success, such as fulfillment, delivery pacing, video completion rates, eCPM, and qualitative reviews of impression delivery by publisher, platform, device, etc. OTT buyers will often seek campaign reach and frequency metrics, as well as brand studies that measure incremental and unique reach compared to linear TV campaigns. While some buyers employ attribution vendors to execute studies related to consumer actions triggered by the campaign, these advanced tactics tend to be reserved for campaigns with large budgets and scale.” Adam Noble, Product Marketing Director, Index Exchange 

We know that client adoption of CTV, especially programmatically, is significantly lower than in the US.  What do you think needs to happen for Europe (or your specific market) to close the gap and encourage more investment in this exciting emerging channel?

“Europe is far more fragmented than the US, and the technology is different. The market in Europe is also different in that it’s dominated by the broadcasters, so for us to catch up with the US we will need the broadcasters to continue their journey towards a programmatic-first mindset. We have seen a significant amount of progress over the past 12 months, but there’s still plenty of work to do. 

Additionally, in the US, there are fewer restrictions on targeting and data. GDPR requires a different approach, but it doesn’t prevent effective targeting. The key thing to understand is it’s not something you go around, instead, you need to work within its boundaries. IDs are a key part of the solution, as they bridge the gap between CTV and other media channels – providing holistic targeting. If broadcasters start to adopt IDs, it will truly unlock the power of CTV.” Patrick Morrell, Director, Inventory Partnerships, The Trade Desk

“In many of the European markets, the education and awareness piece still needs to be worked on. The technology really must work seamlessly and provide the TV-like experience that’s so important to the consumer, the publisher, and the buyer.  

While CTV isn’t exactly programmatic yet, it’s worth noting learnings from the rise of digital display ads (which became programmatic). Display went somewhat down a rabbit hole, as the market quickly developed into a contest about who had built the best one-to-one targeting machine. While some publishers and tech players may well have excellent data sets to enable micro-targeting on CTV, it is essential that CTV respects the empirically proven value of linear TV and that it remains the number one platform to build brands and attain cost-effective reach in a high-quality environment.” Hitesh Bhatt, Director, Publisher Development, CTV, EMEA, PubMatic  

This week's guest editors are Filip Sedefov, Legal Director for Privacy at IAB Europe & Giulia Sala, Senior Associate at DGRS and legal counsel for IAB Italy. In this post, they share their views on the Italian data protection authority's (Garante's) newly published set of guidelines on cookies and other tracking tools. They discuss the new challenges for ID solutions and look at what is strictly necessary to ensure compliance. 

On July 10th, Italy’s data protection authority (the Garante per la protezione dei dati personali - “the Garante”) published a fresh set of Guidelines on cookies and other tracking tools. These new Guidelines complement and specify the Garante’s previous guidelines on the topic, which date back to 2014. The new Guidelines represent the expectations of the regulator when it comes to compliance with Italy’s implementation of article 5(3) of the ePrivacy directive, which establishes a consent requirement for storage and access operations on a user’s device. The final version of the Guidelines comes at the end of a one-month consultation period and six months of analysis of contributions (including from IAB Italy). It follows the publication of guidance on the topic by a number of other prominent European DPAs such as France’s CNIL, Ireland’s DPC, Spain’s AEPD, Denmark’s Datatilsynet as well as - on the topic of GDPR consent specifically - the European Data Protection Board (EDPB). All guidance by DPAs so far is aligned and compatible with IAB Europe’s TCF. Below, we take a brief look at the content of this latest cookie consent guidance by a European regulator, which companies have six months to comply with.

Scope of the Garante’s Guidelines

As mentioned above, the Guidelines refer to the implementation of the consent requirements of the ePrivacy Directive in Italian law (art. 122 of the Personal Data Protection Code). In the digital advertising context, this means they provide indication of the criteria the Italian regulator will use to assess whether or not valid consent was collected by a digital publisher - or their third-party ad tech partners - for storage and access operations on the user’s device, that are related to the delivery and measurement of advertising and content.

Although the Garante’s prior 2014 Guidelines on “Simplified arrangements to provide information and obtain consent regarding cookies” still apply, these were in clear need of an update following the reforms brought about by the GDPR. The regulator explicitly calls out new privacy notice requirements (e.g., data retention periods), more elaborate consent requirements as well as reinforced transparency and accountability principles, and promotion of privacy by design and by default as elements underpinning its updated guidance.

The Garante also clarifies that the Guidelines apply to all tracking tools. It draws a rather detailed and interesting distinction between “active identifiers” (i.e., cookies) and “passive identifiers”, such as fingerprinting or other tracking tools, that do not necessarily presuppose storage of information on the user’s device but are assimilated to such operations for the purpose of its recommendation.

Collecting valid consent

The Garante offers relative flexibility in the implementation of different methodologies for gathering consent. It sets out some best practices in terms of presenting the information to the user while allowing for approaches that deviate from these as long as valid consent can be adequately demonstrated in line with the accountability principle.

The inevitables: scrolling and cookie walls

Although controversial, continued scrolling by the user was considered a valid consent mechanism in Italy for several years, following the entry into force of the GDPR and at least until the EDPB’s Guidelines 05/2020 on consent “officially” invalidated it last year. In these new Guidelines, the Garante addresses the issue of “scrolling” consent directly. Unsurprisingly, the DPA follows the previously established position of the EDPB, indicating that “scrolling” cannot, in and of itself, be considered as constituting valid consent. However, the Garante still - and somewhat more prominently than other regulators - defends its 2014 stance (established namely following efforts by IAB Italy), which is that scrolling may constitute a significant component of a pattern of user interactions that could lead to a positive conclusion about their clear and unambiguous intent to consent.

Similarly, when it comes to cookie walls the Garante also follows the conclusions of the EDPB’s consent guidance (para. 39), which states that “in order for consent to be freely given, access to services and functionalities must not be made conditional on the consent of a user to the storing of information, or gaining of access to information already stored, in the terminal equipment of a user (so-called cookie walls)”. The regulator leaves the door open, however, for a case-by-case assessment of the legality of cookie walls, in cases where the service provider offers the possibility to access equivalent content or services without consent. Still, the inevitable question of whether a paid alternative would satisfy the “equivalent offer” requirement, or under what conditions it would satisfy it, remains unanswered.

What’s in a UI? Consent notice UI requirements

With regard to transparency and user interface (UI) functionality, the Garante - as in its 2014 guidance - maintains an endorsement of consent request by way of a prominent banner or notice (e.g., a CMP UI), presented to users upon their first visit to a digital property. It nevertheless recognises that other methods of obtaining consent are also possible when particular processing requires it, such as through a log-in or authentication process. These pose their own challenges, which we discuss briefly in a separate section further below.

The new Guidelines contain relatively detailed views from the regulator about acceptable UI design, content, and functionality. The DPA recognises, for example, that a UI may be surfaced on different devices and expects UIs to be designed in a way that takes adequate account of the context and environment in which a user is viewing them so that the transparency objective is fulfilled. In addition, the Guidelines specify that user-facing interfaces should, at the very least, respect the following best practices:

• Contain an initial layer with (i) essential information about the cookies and other trackers used and their purpose(s), (ii) an option to close the notice without consenting (e.g. located in the top right-hand corner), including information about the fact that closing the notice is equivalent to a refusal to consent, (iii) an option to consent, and (iv) an option to access a secondary layer with additional information and configuration options concerning purposes and third parties;
• Be easy to resurface, for example through a link at the bottom of each page or dedicated icon that allows users to easily view, access, and modify their preferences;
• Make use of design and colours that are not deceiving, including by using equal text treatment for UI calls to action so that the user is offered clear options and can exercise a free choice.

Where a user takes no action or actively rejects consent, that decision should, according to the Garante, be respected for at least six months. However, the UI can be resurfaced earlier in cases where one or more processing operations or third parties are significantly modified, or where it is impossible to identify what choices the user has made, for instance, because they have deleted the cookies on their device. There is no specified period for storing consent or an indication of when the user should be reminded they can withdraw their consent.

The key: standardisation

On several occasions in the guidelines, the Garante encourages standardisation. In particular, the regulator estimates that users would greatly benefit from standardisation of UI types of commands, colours, functions, and content. The DPA also refers to the fact that dedicated technical cookies can be used to record and maintain the status of a user’s preferences and serve to document their prior actions with regard to such preferences for compliance and accountability purposes.

IAB Europe’s Transparency & Consent Framework (TCF) is the most prominent instrument in the digital advertising context that promotes and operates standardisation precisely around these topics. The table at the end of this blog article attempts to provide a high-level overview and comparison of Garante’s requirements next to those of the TCF. It serves to demonstrate that TCF policies are aligned with the Garante’s latest Guidelines and that the Framework can be implemented in a way that is fully compatible with the regulator’s expectations.

New challenge for ID solutions and enrichment activities?

Interestingly, since the first draft of the Guidelines, a new paragraph has been introduced, which specifically refers to processing activities that accompany the creation of an account or authentication with an existing account. This is raised in the context of alternative methods to collecting consent that do not involve surfacing a banner or notice.

The Garante provides the example of a user accessing a service through the use of authentication or login credentials. It then states that, in such cases, when the account is created, there is an opportunity for the digital service provider (i.e., publisher) to inform the user and request consent for the use of cookies and other trackers. The regulator appears to suggest that, in addition to storage and access consent, users authenticated through login, must be asked to consent specifically to any activity that links different data sets, irrespective of whether these are from the same or different devices. In other words, the Guidelines could be read as effectively establishing a prohibition on the crossing of data relating to navigation carried out through the use of multiple devices, where prior and specific consent has not been obtained. This could be a challenge for ID solutions or any data controllers involved in linking offline and online data. 

An elaborate view on what can be considered as “strictly necessary”

Like the ePrivacy Directive and Italian implementing legislation, Garante’s guidelines make a distinction between strictly necessary technical trackers and so-called “profiling” trackers, used for purposes that are not absolutely required for the operation of a digital property. The question, as always, is what exactly qualifies as a strictly necessary technical storage operation for which transparency must be provided, but which does not require the user’s consent. Interestingly, the Italian regulator goes further in its reflection than others on this point and adopts a slightly more nuanced position, specifically when it comes to first-party analytics.

In short, the regulator is of the opinion that cookies or trackers that serve first-party analytics purposes, can qualify as strictly necessary and hence not be subject to a consent requirement. This is only possible, however, where the following minimisation techniques have been cumulatively applied to these cookies and other trackers:

(i) The possibility of identifying the user is precluded, and they cannot serve to identify a device. The regulator suggests this can be achieved by masking appropriate IP address portions (e.g., at least to the 4th component) so as to introduce sufficient uncertainty in attribution;

(ii) They are used in relation to a single website/app; and

(iii) Third parties intervening in these activities (i.e., who provide the publishers with a measurement service) do not combine such data with other data or statistics of visits to other websites, nor transmit such data to other third parties except in the case where the production of statistics refers to multiple domains attributable to the same publisher (i.e., group’s websites).

Moreover, where a publisher carries out statistical analysis on their own, without the intervention of third parties, they may do so also in relation to multiple domains, websites, or apps, without the above-mentioned minimisation techniques, for as long as such operations do not serve the purpose of making commercial decisions. In essence, this means that a publisher is allowed to carry out ​​statistical analysis on multiple web properties for technical reasons (e.g., deciding on storage and backup requirements) but not for commercial ones (i.e., deciding on digital ad space offering).

Garante’s Guidelines and the TCF

As promised earlier, below is a table that offers a high-level view of how some of the requirements in Garante’s new Guidelines compare to those set out in IAB Europe’s TCF. As always, it’s useful to keep in mind that TCF Policies set a minimum standard and that organisations should, in addition to TCF, implement more stringent requirements where these exist locally.

In this week's member-guest post, we hear from Stephanie Hanson, Offering Manager at OneTrust as she explores the CTV landscape and shares privacy best practices to follow. 

The time has finally come to cut the cord.  Internet streaming TV models are quickly becoming the norm worldwide compared to past cable TV models. At the same time, privacy regulations are popping up around the world, requiring companies to adjust their digital privacy experiences based on different requirements. How can companies jump into the CTV space and confidently adhere to privacy guidelines while meeting consumer expectations in regards to how their data is collected and shared? Read this article to find out. 

Dipping into the CTV Pool 

A streaming service can provide consumers with video, audio, or other content delivered online. Just a few examples of the more popular streaming services include Amazon Prime, Hulu, and Netflix. In fact, half of Americans (60% of them young adults) access video content through online streaming services. 

With a growing number of consumers utilising streaming services, publishers shouldn’t overlook these outlets as an opportunity to advertise. Many publishers already have taken advantage of this new revenue stream, with 60% of Digital Buyers saying that they’ll shift Linear TV dollars to Connected TV (CTV) advertising in 2021).  Whereas OTT (over-the-top) is the delivery method for streaming content, CTV (ConnectedTV) is the device on which the streaming services run.  Advertisers can purchase ad space from publishers to display across OTT services and CTV applications.  

Targeting and efficiency are two of the main benefits publishers and advertisers can hope to see by investing in CTV advertising. However, there are plenty of other advantages of adopting this new strategy. While CTV is a new channel that companies are tapping into, it’s essential to understand requirements that accompany OTT and CTV, especially when it comes to data privacy.

Benefits of CTV Advertising

One reason advertisers are shifting towards CTV advertising is that it is an effective method for reaching target audiences. Because of the nature of streaming services, content is already topic-specific. If you know the demographics and psychographics of your audience, there’s a good chance you can locate them and show them highly targeted ads via the content they’re consuming on CTV. 

Advertisers can reap the benefits of CTV advertising by taking a cross-channel approach.  Advertising can now span across your website, social media sites, mobile devices, and OTT platforms. 

Brands that focus on multi-channel advertising report an average 500% improvement in ROI.   It’s not hard to be convinced of the value of CTV advertising. However, with any new advertising outlet, there are always some unknowns. 

CTV Advertising and Data Privacy 

While CTV advertising certainly is an exciting new advertising venture for publishers, we shouldn’t forget the importance of privacy.  As these are new advertising arenas many publishers are still navigating what best privacy practices look like when it comes to OTT and CTV. This new landscape includes a whole ecosystem of partners and vendors who are now receiving personal information.  

Consent and privacy strategies should always be at the forefront of planning and incorporated into OTT and CTV platforms. Just like other marketing channels, it is critical to ensure transparency and provide consumers with choice over data collected for advertising purposes via streaming.  

In addition to this, publishers leveraging the IAB TCF (Transparency and Consent Framework) v2.0 framework must ensure they are using a verified CMP, such as OneTrust, to appropriately capture consent and preferences to effectively signal it downstream to ad tech vendors.

Although implementing privacy-first practices should be well-thought-out it is always well worth the while.  Some of the benefits include honouring consumer privacy and creating a trusted brand relationship with consumers through transparency. Additionally, consented inventory can lead to higher revenue for publishers.

Conclusion: Rely on CTV Privacy Technology

The potential in CTV advertising for publishers is exciting. By providing viewers with a seamless user experience while respecting their data preferences, you have a good chance of making this channel a viable consented revenue stream. 

CTV app consent technology is your golden ticket to achieving compliance with privacy regulations while also meeting your advertising goals.

According to the recently released AdEx 2020 study, the European digital ad market is now programmatic first with 50.6% of all display spend now transacted programmatically.

Programmatic is a big deal. But to really understand the status of programmatic adoption across Europe on both the buy and the sell-side of the digital advertising industry, we need your help. IAB Europe is inviting all stakeholders, from advertisers and agencies to ad tech and publishers, to answer the 2021 Programmatic Survey! Take part here. 

Now in its seventh year, this survey aims to illustrate the current adoption of and attitudes towards programmatic advertising. The results will help inform the IAB Europe Programmatic Trading Committee that provides guidance on developing a programmatic advertising strategy for publishers, agencies, and advertisers.

The deadline to complete the survey is Friday 6th August and it takes just 10 minutes to complete. Plus your response will be treated in the strictest confidence and all respondents will be sent a copy of the 2021 report with full results.

Help us uncover how programmatic advertising attitudes, adoption, and strategies are evolving. Take the survey today!

Check out last year's report to see what the findings provide so much value and insight.