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    European Cookie Law, from TCF 2.0 to TCF 2.2: what changes

    User profiling
    european cookie law novità

    Following the enactment of the GDPR and the emergence of Consent Management Providers (CMPs), IAB in 2018 developed and published the Transparency and Consent Framework (TCF) with the aim of standardizing the process of obtaining consent to cookies by providing information about the same to users.

    The Blendee team discussed this at the latest meeting organized by IAB TechLab in London at “Rearc: Build for Privacy Series.”

    CMPs based on the IAB TCF determine the specific uses and make explicit the advertising partners to which you have consented.

    Specifically, three parties come into play in the use of the TCF framework: publishers, i.e., the first point of contact for users the one where interaction with advertising content takes place; vendors, i.e., advertisers (vendors); and the Consent Management Provider who provides the technology and ensures that consent is obtained.

    In this process, the IAB TCF framework functions as a communication system that mediates user consent statements between the publisher, vendors, and the CMPs used on the publisher’s website.

    Compared with the first IAB TCF 2.0 version, the new version of the IAB TCF 2.2 framework includes updates that address the following points.

    • Legal basis: in TCF 2.0, vendors could indicate either consent or legitimate interest as the legal basis for purposes 2 to 10. In contrast, in TCF 2.2, legitimate interest is no longer an acceptable legal basis for purposes 3, 4, 5, and 6. Consequently, for these purposes, Vendors can now rely only on consent.
    • User-friendly text: TCF 2.2 introduces improvements in names, descriptions, and explanations of purpose and functionality. All this allows users to have clearer and more understandable consent information.
    • Introduction of a new purpose: Purpose 11 (Use of limited data for content selection) was introduced, designed to cover processing activities such as selecting and providing non-advertising content based on real-time data and controlling the frequency or order in which content is presented to the user
    • Added vendor information: vendors with the new framework are required to provide information on how they process data, e.g., categories of data collected and retention period. In addition, CMP platforms are now required to report the total number of vendors.
    new TFC framework

    In addition to these new features, it is important to mention that TCF 2.2 reiterates the importance of preserving user control: in fact, publishers and CMPs are required to ensure that users have the ability to revoke consent given at the initial stage even afterwards.

    In addition to policy changes, TCF 2.2 compared to the previous version also contemplates technical specification updates such as saying goodbye to the getTCdata command and upgrading GVL (Global Vendor List) to version three.

    After a transition process that began in May 2023 with the launch of TCF 2.2, November 20 is the date chosen as the deadline for its implementation: CMPs and vendors are required to implement the new guidelines.

    The goal pursued by IAB Europe is to ensure the right balance between privacy, protection of personal data and effectiveness of campaigns, allowing them to be personalized and targeted, while respecting the two aspects mentioned above.

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