Interactive Advertising Bureau
28 April 2023

Remarks for Delivery by Townsend Feehan, CEO, IAB Europe at the DG JUST Stakeholder Roundtable on the Initiative for a Voluntary Business Pledge to Simplify the Management by Consumers of Cookies and Personalised Advertising Choices, Friday 28 April

A note from IAB Europe's CEO, Townsend Feehan on her remarks for delivery at the DG Just Stakeholder Roundtable on the Initiative for a voluntary business pledge to simplify the management by consumers of cookies and personalised advertising choices.


Thank you for the invitation to attend today (Friday 28th April) and the opportunity to participate in DG JUST’s reflection over the coming months. 

In my speaking time, I would like to call out two assumptions in the Discussion Note circulated in advance of today’s meeting that are worth bearing in mind, and two ways that IAB Europe can support the reflection. 

First, the Discussion Note helpfully acknowledges that personalised advertising delivers benefits to both consumers and advertisers.  The reality is that personalisation is attractive to advertisers because it offers the prospect of less wasted spend; the Discussion Note explicitly suggests that consumers understand and accept this fact. 

Second, the Discussion Note’s  focus on improving information to consumers seems to confirm DG JUST’s continuing faith in the information-and-choice paradigm for European consumers on which existing privacy and data protection law are based (as opposed to contemplating a different paradigm that would take choice and control out of consumers’ hands).

These seem to us to be important and positive foundational assumptions.

With respect to how IAB Europe can support the reflection that is being kicked off today, we believe we are well-placed to contribute to each of the two key areas of focus laid out in the Discussion Note. 

First, with respect to information to be provided to consumers,  IAB Europe can help give practical effect to a future DG JUST pledge by ensuring that its Transparency & Consent Framework (TCF), which is implemented on hundreds of thousands of EU websites,  integrates additional information disclosures.  TCF is a best-practice minimum standard that helps websites solicit, establish, record, and signal a GDPR legal basis and ePrivacy consent for data processing for advertising. The TCF  dialogue box that opens when a user visits a website or app for the first time could be modified to include an explicit reference in the first layer to the site being “ad-funded”, or “partially dependent on advertising revenue”, or “ad-free and subscription-based”. The dialogue box could also explicitly state that content is offered in exchange for a willingness to receive advertising.  TCF UIs already indicate what “trackers” or other personal data the website or app is asking for user agreement to process,  for what purpose(s), and the legal basis/es for processing (whether consent or legitimate interests) if the user agrees.   

Second, with respect to exploring “alternatives to tracking-based advertising” that are also personalised in some way, we can provide insight into the state of play on the industry’s own work to identify and further develop alternatives to third-party cookies and help the stakeholders participating today understand the implications of that work for consumers.  As DG JUST and other colleagues here today will be aware, there are already alternatives (for example, personalisation based solely on context) and work to identify means of personalising advertising that do not involve the use of cookies has been accelerated in recent years by technology and business decisions taken by browser and operating system manufacturers.  

It is important that this reflection be clear-eyed about there being winners and losers in any evolution of the paradigm.  As an example, arguably contextual advertising works for eCommerce platforms, single-topic or ‘niche’ sites, and large news sites that have the resources to run sports and lifestyle feature sections, but less well – or not at all – for smaller news sites that do not have those resources.  Even large news organisations using only contextual would need to let a great deal of content go “unmonetised” as it is difficult to match advertising content to serious news content.  Similarly, certain news media platforms cannot build commercially attractive audience segments based solely on first-party data due to their content being limited to “serious” news, user engagement with which reveals nothing about a product or service that someone might be interested in buying. 

And when specific categories of online actors “lose”, the consumers that have benefited from free or low-cost access to their content and services also lose.  

IAB Europe would be pleased to host a workshop to which DG JUST and all attendees of today’s Roundtable would be invited to present the state of play on the development of these alternative models.  I hereby formally extend that invitation.   

We are looking forward to participating in this important reflection between now and the end of the year.

Thank you again,

Townsend Feehan, CEO, IAB Europe

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