European regulations overview and guidance

Interoperability guidance for vendors working with Google via the IAB Europe TCF

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Google does not require ad technology providers to adopt IAB Europe TCF. This article describes how Google interoperates with those ad technology providers who have chosen to adopt IAB Europe TCF, and does not apply to those who have not adopted IAB Europe TCF. Ad technology providers who have chosen not to adopt IAB Europe TCF should adopt Additional Consent.

What to know before registering

If you are integrating with the IAB Europe TCF, please review the information below about how Google will interoperate with the IAB Europe TCF based on the content of the IAB Europe TCF’s Transparency & Consent (TC) string. Google may update this information from time to time.

For simplicity, we use the phrase 'Google will work with you via the IAB Europe TCF' below to encompass several aspects of interoperability via the IAB Europe TCF, including but not limited to:

Bidding on bid requests that Google receives
Sending bid requests from publishers using Google to bidders
Allowing third-party ad tracking and third-party ad serving to occur

Google policies

The interoperability guidance below is intended to reflect Google's existing policy requirements, in particular the requirements of Google's EU user consent policy and our policies against fingerprinting for identification (for example, those contained in our Requirements for third-party ad serving). Please note that our policies continue to apply and are more restrictive than IAB Europe TCF policies in some cases.

Purposes

For each purpose below, for Google to work with you via the IAB Europe TCF, the TC string must indicate that consent has been granted by, or legitimate interest has been established with, the user (as applicable).

Store and/or access information on a device (Purpose 1)

If you use cookies, mobile ad identifiers or other local storage, Google will work with you via IAB Europe TCF if you are registered for consent for purpose 1.

In some jurisdictions, for example Switzerland, in certain situations, consent for Purpose 1 may not be asked for by the publisher via the CMP and, so long as the TC string appropriately represents this, Google will interoperate in those situations. In line with our EU user consent policy, this position is subject to change based on legal developments and evolving regulator guidance.

Use limited data to select advertising (Purpose 2)

Google will work with you via IAB Europe TCF if you are registered for ‘consent’, ‘legitimate interest’, ‘consent or legitimate interest’ or ‘not used’ for purposes 2.

Create profiles for personalised advertising and Use profiles to select personalised advertising (Purposes 3 and 4)

Google will work with you via IAB Europe TCF if you are registered for ‘consent’ for purposes 3 and 4, so long as the TC string indicates that the user has granted consent for both those purposes.

Google will also work with you via IAB Europe TCF if you are registered for ‘not used’ for these purposes.

If you're registered for ‘legitimate interest’ for purposes 3 and/or 4:

If the TC string indicates that ad personalisation (purposes 3 and/or 4) is permitted under legitimate interest, Google will not work with you via IAB Europe TCF.
If the TC string indicates that no ad personalisation is permitted, Google will work with you via IAB Europe TCF.

If you're registered for ‘consent or legitimate interest as a legal basis’ for purposes 3 and/or 4:

If there are no publisher restrictions, Google will work with you via IAB Europe TCF so long as your default legal basis is consent.
If there are publisher restrictions:
- If the publisher restriction is for you to operate on the basis of consent, Google will work you via IAB Europe TCF in that circumstance.
- If the publisher restriction is for you to operate on the basis of legitimate interest, Google will not work with you via IAB Europe TCF in that circumstance.

Measure advertising performance (Purpose 7)

Google will work with you via IAB Europe TCF if you are registered for ‘consent’, ‘legitimate interest’, ‘consent or legitimate interest’ or ‘not used’ for purpose 7.

Understand audiences through statistics or combinations of data from different sources (Purpose 9)

Google will work with you via IAB Europe TCF if you are registered for ‘consent’, ‘legitimate interest’, ‘consent or legitimate interest’ or ‘not used’ for purpose 9.

Develop and improve services (Purpose 10)

Google will work with you via IAB Europe TCF if you are registered for ‘consent’, ‘legitimate interest’, ‘consent or legitimate interest’ or ‘not used’ for purpose 10.

Special Purposes

Ensure security, prevent and detect fraud and fix errors (Special Purpose 1)

Google will work with you via IAB Europe TCF if you are registered for ‘legitimate interest’ or ‘not used’ for special purpose 1.

Deliver and present advertising and content (Special Purpose 2)

Google will work with you via IAB Europe TCF if you are registered for ‘legitimate interest’ or ‘not used’ for special purpose 2.

Features

Match and combine data from other data sources (Feature 1)

Google will work with you via IAB Europe TCF if you register for feature 1, so long as appropriate disclosure has been provided to the user.

Link different devices (Feature 2)

Google will work with you via IAB Europe TCF if you register for feature 2, so long as appropriate disclosure has been provided to the user.

Identify devices based on information transmitted automatically (Feature 3)

Google will work with you via IAB Europe TCF if you are registered for feature 3. However, we remind you that our policies prohibit fingerprinting for identification (e.g. Requirements for third-party ad serving), and we require that you adhere to our policies, which can be more restrictive than the IAB Europe TCF in some cases, whenever you work with us.

We actively enforce our policies and we're continuing to invest in technology to detect fingerprinting on our platforms.

Special Features

Use precise geolocation data (Special Feature 1)

Google will work with you via IAB Europe TCF if you register for this feature, so long as appropriate disclosure has been provided to the user and users appropriately opt-in to special feature 1.

Actively scan device characteristics for identification (Special Feature 2)

Google will work with you via the IAB Europe TCF if you are registered for Special Feature 2. However, we remind you that our policies prohibit fingerprinting for identification (for example, Requirements for third-party ad serving), and we require that you adhere to our policies, which can be more restrictive than the IAB Europe TCF in some cases, whenever you work with us.

Macro requirements

To adopt the IAB Europe TCF, macros should be added to pixel URLs within creatives to indicate where in the URL the TC string should be inserted and sent onwards, as well as to identify which vendors are present.

For any help or support with IAB Europe TCF registration in general, independent of Google’s integration, please email IAB Europe at framework@iabeurope.eu.

FAQs

Scope

Which Google ads products are integrating with the IAB TCF v2.0?

Integration with the IAB TCF v2.0 will apply to third-party inventory (not Google owned and operated inventory). We obtain consent for Google owned and operated inventory through our own consent flows.

Products that will be integrated with the IAB TCF v2.0:

Google Ad Manager
AdSense
AdMob
Google Analytics (for advertising features used in conjunction with Google ads products)
Google Display Ads (for integrated properties)
Display & Video 360 and Campaign Manager 360 (for integrated properties)
Google Authorised Buyers
Funding Choices

Timing

What is Google’s GVL ID and when this will be visible in the TCF framework?

Google’s GVL ID is 755. Google has been officially listed in the IAB’s GVL since 23 July 2020.

Although Google is listed in the GVL, we will not begin reading and passing TC strings until our integration launches. We plan to start ramping up TCF serving two weeks before our full integration launch date, which is targeted for 15 August 2020

Integration requirements

What are Google registration requirements?

There are two things to distinguish:

Google registration as a vendor. Please see the IAB TCF GVL registry (.JSON file) for Google’s registration as a vendor.
Google’s requirements for vendors and publishers to work with Google. Please refer to Google’s Interoperability guidance for vendors.

Can publishers using the IAB TCF v2.0 continue to work with vendors that are not registered on the GVL after Google’s integration is complete?

We will continue to support ad technology providers that are certified on our platforms but not registered on the GVL through 'Additional Consent', which is a technical spec that CMPs can implement to add Google’s ad technology providers (ATPs) to consent messages.

CMPs must implement this spec for publishers to continue working with vendors on Google’s ATP list that are not on the IAB GVL.

Why does a publisher need to obtain consent for both Purpose 3 (Create a personalised ads profile) and Purpose 4 (select personalised ads) to serve personalised ads? What if a publisher wants to personalise ads for that user, but not build personalised profiles for them?

Based on our interpretation of the GDPR and ePrivacy Directive requirements, various guidance from the Article 29 Working Party and our own dialogue with DPAs, we have come to the settled conclusion about the appropriate lawful basis. Further details on the nature and scope of processing including the applicable legal basis are also described in the Privacy Policy.

Google has not changed its consent requirements in relation to the TCF. Google customers (e.g. publishers and advertisers) using Google ad platform products must comply with Google’s EU user consent policy.

Without consent for Purposes 3 and 4, Google will not be able to offer personalised ads. Specifically, with just consent for Purpose 4 and no consent for Google for Purpose 3, only non-personalised ads will serve. These requirements are in line with our existing Google EU user consent policy which states:

You must obtain end users’ legally valid consent to:

the use of cookies or other local storage where legally required [Purpose 1]; and
the collection, sharing [Purpose 3] and use [Purpose 4] of personal data for personalisation of ads.

Google Ad Manager publishers can choose in the user interface to enable or disable whether or not user visitation data can be used by Google to help create user interest categories in order to target ads. Disabling these settings does not prevent publishers and RTB buyers from serving personalised ads, although publishers will still need to obtain consent for Purposes 3 and 4.

What would happen if a publisher decides to not integrate the TCF V.2 and send the consent to Google as they are doing right now?

Google is not integrated with TCF v1.0, so Google will continue to ignore v1.0 TC strings as if they were not there.

Partners are not required to use IAB TCF v2.0. They can continue using other means to comply with our policies.

The ad technology provider controls that we launched across Ad Manager, AdSense and AdMob last year for publishers will continue to function.
When setting up their IAB-compliant CMPs and picking which ad technology providers (ATPs) they want to work with, publishers monetising with Google can select vendors IDs from both IAB’s Global vendor list and Google's ATP list for any CMPs that implement Additional Consent. If there are vendors that are not available on the IAB GVL but are available in our ad technology provider controls, publishers can continue to work with those ad technology providers.

We will only support ad technology providers that are present in our controls as our certification process is still in place and vendors must be certified to run ads programmatically. Our certification process has always been open. If there are vendors on the IAB Global Vendor List that are not in our ATP controls, they will not serve.

Is AMP integrating with the IAB TCF?

AMP supports popular transparency consent frameworks including the IAB TCF v1.0, TCF v2.0 and the IAB US Privacy String. Please check with your consent management platform (CMP) and ad networks on their AMP support. AMP will read and pass the strings passed by the frameworks (IAB TCF v1.0, TCF v2.0 and the IAB US Privacy String) when received by CMPs/ad networks. Learn more about AMP and consent

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