On June 30th, the IAB Europe’s Transparency & Consent Framework (TCF) 2.0 finally arrived, bringing a mixture of welcome changes for publishers and some concerns. With the revamp comes revised guidance to standardise how players across the digital ecosystem can run programmatic advertising in a GDPR-compliant way, as well as improvements and new features.
Versions 1.0 and 1.1 were widely considered as fully controlled by ad tech vendors at a publisher’s expense, particularly with the justification for data processing activities. Now, v2 not only offers clearer consumer choices, but it also enables publishers to dictate which vendors can process data for certain purposes – and how – instead of giving blanket permissions.
But these alterations aren’t the biggest news about TCF 2.0. What’s driving most interest is that Google has decided to take part, on August 15th, two-and-a-half years after GDPR enforcement.
Originally considered the missing link, Google’s participation is being hailed as vital; adding influence and legitimacy that will encourage others to sign up. But Google’s presence brings other constraints. A closer look at its updated TCF policy and requirements reveals unfair practices that could deeply hurt publisher revenues and lessen data control.
So, is Google simply getting on board with an important industry initiative, or is it set to hijack the framework to further advantage itself and harm publishers?
The personalisation trap: ads for data
By now, almost every publisher knows how the TCF works: providing a universal way of communicating how data should be used across the supply chain — including specific user preferences — via the transparency and consent (TC) string. Thanks to recent adjustments in the 2.0 edition, publishers have a greater ability than ever to manage audience privacy by customising TC strings and setting their own restrictions for ad tech partners.
For example, if publishers don’t wish to allow specific processing purposes, they could block them by default and leave them out of TC strings, inherently preventing vendor use.
Google, however, has outlined certain requirements that will limit this control, especially when it comes to one of the most rewarding areas for publishers; personalised ads.
Its policy document states ad requests will only be progressed if publishers meet key stipulations; including end user consent for Google to create personalised ad profiles. Technically speaking, the ability to build individual profiles isn’t necessary for displaying tailored ads. As a result, it looks like Google’s core motivation is protecting its own interests by presenting publishers with a difficult choice. Either they can place limits on data use to protect user privacy and data leakage, or give permissions that allow Google to keep tapping their audience data to perform further enrichment, in exchange for delivery of personalised ads.
Chances are high that the majority of publishers will have to accept this bargain. Not only are many monetization models built around Google’s personalized advertising, but the revenues it drives are particularly important amid current COVID-19 pressures. All of which will mean Google is in an even stronger position to harness its existing dominance, gain even greater power, and continue to plunder publisher data across Europe.
Non-personal ads aren’t safe either….
On the surface, these provisos seem at odds with Google’s recent efforts to help publishers; including waiving ad serving fees for a select number of news publisher clients as part of an initiative to support journalism during the pandemic. But the reality is that ad serving is the tiny, visible, aspect of the media giant’s fees — accounting for no more than 3% of its total “ad tech tax”— and won’t make much difference to Google’s bottom line. That’s not to mention the disadvantage this move creates for independent competitors who lack the resources to match it.
The overall picture is of a two-sided strategy where generous gestures are being made on one hand, while Google bolsters its data stores with the other; and it’s one that becomes clearer when attention turns to the other key pillar of its TCF policy — non-personalised ads. Once more, ads will only be served if all requirements are met and the list features two familiar criteria: end user permissions for storing and accessing data on devices and market research.
According to Google, the main reason behind these requirements is the ongoing need for cookies or mobile identifiers to “combat fraud and abuse, for frequency capping, and for aggregated ad reporting.” Although consent is needed to store cookies under GDPR rules, there is nothing to technically or legally prevent delivery of ads without cookies when they are aligned with surrounding content and don’t use personal data or frequency capping.
Again, Google is providing publishers with a tough decision. In the wake of rising constraints on third-party cookies from popular browsers, publishers may be keen to reduce their cookie reliance and focus on alternatives such as contextual ads. But opting to go cookie-free and stop asking for consent will cut them off from all demand in Google Ad Manager (GAM), effectively acting as an ad blocker. While yield from non-personalised ads is admittedly much smaller — often 70% lower — this still adds up to a large hole in publisher profits.
When we look at the cookie consent rate from users across several European countries, where GDPR applies, but with local differences in terms of consent UX requirements, Smart’s own data suggests the rate can vary from 40% (in Greece for instance) to 90% or 95% (in Spain for example, which allows soft consent). A publisher operating in a country with strong requirements can lose up to 60% of its inventory with GAM.
To combat negative feedback from publishers, Google is set to launch its “Limited ads” feature, which will allow the delivery of ads for users refusing cookies. However, it’s doubtful this solution will help publishers monetize their inventory because, when a user denies a CMP, all purposes are blocked in a grouped manner. For example, it’s unlikely consumers would deny cookies but then accept “basic ads”. As such, the value proposed by such an offering is zero, with publishers who use Google Ad Manager still unable to serve ads when there is no consent.
There are numerous other examples of how Google exerts its dominance to the detriment of publishers, such as the investigation by the Australian Competition and Consumer Commission into the control Google has over other media owners by controlling traffic sources. Similar cases in Europe haven’t previously proved successful but the proposed outcome from Australia would provide news publishers additional bargaining power with the likes of Google.
Is there another way?
The best solution to this complex array of problems is simple. To evade Google’s demands, publishers should take their business – and ad space – elsewhere. In other words, publishers need to work with neutral, independent platforms that aren’t quietly seeking to promote their own inventory and harvest or retarget audiences. Data should always stay with its owner and, as the case of Google shows, there is no surer sign that an organisation is out to enhance its own success than convoluted rules and procedures designed to relieve publishers and partners of their valuable data assets.
Of course, just a few weeks into the official launch of TCF 2.0 and Google’s entrance, it’s too early to tell exactly what will happen. But there is plenty of evidence to suggest the media mogul is primed and ready to use the new framework to enhance its advantage. For publishers, it’s crucial to keep a close eye on how this latest iteration and the Google partnership pans out. Bearing in mind that if they want to release the control, clarity, and freedoms the TCF is meant to offer, their optimal route isn’t likely to lie with Google.
Chief Privacy Officer, Smart AdServer
Smart AdServer is a leading independent ad monetization platform built for premium publishers to serve demanding buyers. Our fully transparent platform and shared-interest business approach enables premium publishers and brands to get their fair share of ad value at every opportunity, on their terms. Smart works directly with more than 1,000 publishers worldwide including Groupe Marie Claire, TracFone, Le Figaro, Leboncoin, Altice Media Publicité, and IMGUR to deliver display, video, native, and rich-media ads to over 50,000 sites and apps.