- From: Harshvardhan J. Pandit <me@harshp.com>
- Date: Wed, 16 Jan 2019 22:28:25 +0000
- To: Eva Schlehahn <uld67@datenschutzzentrum.de>
- Cc: public-dpvcg@w3.org
- Message-ID: <43008175-cfaa-22ba-cc93-e09a8a1444f0@harshp.com>
Hi Eva, I'm sharing here my notes about IAB. The official link to their consent representation is https://github.com/InteractiveAdvertisingBureau/GDPR-Transparency-and-Consent-Framework/blob/a32574941ce201708e30e78702278efe1ce6cd59/Consent%20string%20and%20vendor%20list%20formats%20v1.1%20Final.md Main items of interest in that are their list of purposes (5) and something called features (3), the way they register 'vendors' - which can be either Controllers or Processors. IAB Consent String Interactive Advertising Bureau (IAB) is an industry association that develops standards for the digital advertising industry. IAB provides an open-standard framework for the management of consent called Transparency and Control Framework (TCF). The TCF has its own terminology distinct from that of the GDPR such as * 'vendors' - which are third-parties with access to the user's device or data, but are not necessarily Data Controllers * 'CMP' Consent Management Provider - provides consent management between websites and vendors consent string: * In TCF, obtained consent is represented using a standardised binary representation known as 'consent string' and is distributed to vendors using a real-time bidding mechanism known as 'daisybit'. * IAB maintains a list of approved/registered vendors and CMPs * IAB maintains a list of 'standard' purposes used for consent, of which currently there are 5 * The metadata stored within the consent string reflects information such as when it was updated, compression scheme of the data, and version of vendor list it uses. * The list of purposes and vendors the consent is given for are represented by a set bit in a binary string. * After the interaction between an end user and the Consent Manager Provider (CMP) UI, the consent info is stored (for example, as a third-party cookie) in the user's browser. The data in the consent string answers the question: "Which vendors and purposes did the user give consent for?" compliance: * an audit of the given consent can be presented using consent string which contains the recorded timestamp of last update, cmpid (which CMP), cmpversion (which version of CMP), consent screen (screen number in CMP), consent language, vendorlistversion, list of (approved) purposes and vendors * Where should a CMP store the user consent information for long-term storage? o Cookies + pros: Easy to use and cheap; Fast and provide a good user experience + cons: Short-lived; Cannot be used as proof of consent; Third-party cookies might be blocked by browsers so web-wide consent can be hard to implement o Server-side storage + pros: Long-lived; Can be used as proof of consent + Can be slow (use cookies/local storage as client-side cache); Requires a long-term ID (cookie ID or email or similar user ID) o You'll usually want to go with a combination of server-side storage for being able to store consent for a long time and share it across websites/apps, and a client-side storage like cookies or shared preferences for a local fast-to-access cache. o A third-party cookie is not a long-term solution to auditable, permanent, user-keyed consent storage, and does not work today for browsers that block 3rd-party cookies or mobile apps. CMP's should work towards standardizing a more future-looking server-side consent retrieval mechanism as well, and can use this cookie as "consent caching" for that future implementation. * revoking consent o The IAB Europe Framework only expresses user consent at a given point in time. o A state change (for example, revoked consent) can be determined by comparing user consent records.(no information on what this means or how to do this) o The Framework does not deal with other GDPR rights like portability, the right to be forgotten, etc. o Signals sent through the IAB Europe framework should only indicate what the user status is at the time of the signal creation and nothing else. The CMPs and vendors should deal with other GDPR rights separately and on their own for now. Regards, Harsh On 08/01/2019 15:21, Data Privacy Vocabularies and Controls Community Group Issue Tracker wrote: > dpvcg-ACTION-58: Look at iab europe consent framework > > https://www.w3.org/community/dpvcg/track/actions/58 > > Assigned to: Eva Schlehahn > > > > > > > > -- --- Harshvardhan Pandit PhD Researcher ADAPT Centre Trinity College Dublin
Received on Wednesday, 16 January 2019 22:33:37 UTC