The Transparency and Consent Framework (TCF) consists of Policies and Technical Specifications that assist all companies in the digital advertising supply chain to meet transparency and user choice requirements related to data processing.
Like TCF v1.1, TCF v2.0 is designed to standardise the collection and transmission of user choice and transparency on digital properties so that the digital advertising supply chain can align with GDPR and ePrivacy requirements. However, TCF v2.0 takes better account of Publishers’ needs as well as the evolving legal requirements and expectations from regulators. Publishers employing TCF v2.0 also gain greater control and flexibility with respect to how they integrate and collaborate with their technology partners. New publisher functionality allows them to restrict the purposes for which personal data is processed by vendors on a publisher’s website on a per-vendor basis.
In this blog post dedicated to publishers, IAB Europe’s Privacy and Compliance Manager, Ninon Vagner, summarizes some good practices that can help to successfully implement TCF v2.0 before August 15, the cut-off date of the technical support for TCF v1.1.
Learn about the Policies and Technical Specifications : As a Publisher, you do not need to register or pay to participate in the TCF. You can adopt and use the Framework in association with its content as long as you adhere to the Policies and the Specifications. Among other things, this means that you must publicly attest that you are committed to complying with the TCF Policies and Specifications and indicate the IAB Europe-assigned ID of the Consent Management Providers (CMP) that you are using in a prominent disclosure, such as in your privacy policy.
Start with a CMP : Consent Management Providers (CMPs) offer interfaces for users to set their preferences for purposes and vendors. These choices are saved in the Transparency & Consent String (TC String), which is accessible to vendors registered with the TCF. You can either utilise the services of a commercial CMP registered with the TCF or build your own CMP and register as a private CMP in the TCF.
Take advantage of Publisher Purposes : If you need to establish legal bases for your own data processing purposes, you can leverage the Publisher TC segment of the TC String to save user choices for Publisher purposes transparency & Consent. The Publisher TC segment of the TC string supports the standard list of purposes defined by the TCF as well as custom purposes.
When a third-party is acting as your data processor on your digital properties, you can instruct them to verify the signals communicated by the TC String for your own purposes prior to storing and/or accessing information on users’ devices or processing personal data.
You can collect the relevant TCF signals as new parameters to flag users’ data you collect, and apply logical filtering for each of your in-house data processing activities.
Implementing Publisher Restrictions : TCF v2.0 enables you to specify custom requirements, such as allowing only consent to be used as a legal basis on your properties for a limited set of Vendors for a given purpose, to align with your legal considerations and business strategy. Connect with your direct and preferred vendors to verify what legal bases they seek to establish for processing toward a purpose, and check the essential legal bases requirements for each of their products or services. When a Vendor has declared two possible legal bases (flexible legal bases) for a particular purpose, it will rely on the legal basis instructed by your publisher restrictions, and otherwise rely on the default legal basis it has declared. You can access the full list of registered Vendors here.
It will enable you to adapt the CMP you use accordingly, provide proper interoperability with them and ensure the smooth continuation of your digital operations. Do not hesitate to test your CMP’s configuration before deploying it to all your users.
Update Vendors’ technologies on your properties : The TCF v2.0 Policies require Vendors to adjust their software for use by Publishers, such as scripts and tags that result in personal data processing or the storing and/or accessing of information on user devices. Before switching to TCF v2.0 check if these vendor updates require an update on your property.
Read the available support and guidance materials : To support Publishers implementing TCF v2.0, we have prepared marketing materials and collaterals that provide an overview of the framework, its mechanisms, and what it entails for all stakeholders. From videos to handy guides, you will find everything you need to familiarise yourself with TCF v2.0 and its latest updates. You can access all materials here.
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