- 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
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--
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Harshvardhan Pandit
PhD Researcher
ADAPT Centre
Trinity College Dublin
Received on Wednesday, 16 January 2019 22:33:37 UTC