IAB UK response on Transparency and Consent Framework: following suspension of Vectaury and announcement of Consent Management Platform validator tool

December 2018

Vectaury, the French location-based start-up, has recently been suspended from the IAB Europe Transparency and Consent Framework (TCF) as a Consent Management Platform (CMP).

The suspension follows the decision by the French data protection authority, the Commission Nationale de l’Informatique et Libertés (CNIL), that Vectaury’s CMP failed to obtain valid consent under the GDPR.

When companies register to be recognised as a CMP, they commit to comply with the policies that inform the TCF. The CNIL decision revealed that Vectaury had not followed these policies, for example, Vectaury had not provided a link to a list of named companies wishing to process user data, nor the specific purposes for doing so on the first screen of the CMP UI, as instructed by the TCF Policies. Instead, users had to click through several layers to find this information.

In response to this suspension IAB UK made the following statement.

 “Following the recent decision by CNIL, questions were asked about why Vectaury, who claimed to have implemented the TCF, were deemed to be in breach of the GDPR. Had Vectaury followed the TCF Policies more closely, many of the points the CNIL identified as being shortcomings would not have arisen. As the decision highlighted Vectaury’s failure to meet requirements it had agreed to adhere to when it signed up as a CMP, it was necessary for IAB Europe to suspend Vectaury from the TCF. However, our colleagues will be working with them to address the issues raised and hope they can be re-instated as a CMP soon”.

IAB Europe is developing a compliance programme for CMPs to ensure that they are complying with the TCF. A key part of this initiative will be a CMP Validator tool which will enable a comprehensive review of all CMPs registered in the TCF and will check for compliance with the TCF Technical Specification. The compliance programme will be an ongoing process and will proactively identify non-compliant CMPs who will be given a deadline to comply, or face suspension from the Framework.

Under the direction of IAB Europe’s recently appointed Director of Technology, Patrick Verdon, IAB Europe will continue to issue more prescriptive guidance to CMPs and publishers on the TCF, which will provide further clarity and transparency to the digital advertising industry.

There are currently 169 registered CMPs, with the Transparency and Consent Framework implemented on over 100,000 websites. As a result, it is estimated that approximately 30 percent of all programmatic ad calls originating from European websites carry a TCF consent string.