
Recently, the Court of Justice of the European Union (CJEU) issued a ruling that directly affects the Transparency & Consent Framework (TCF) by IAB Europe. Here’s what is changing and how our team at My Agile Privacy is working to keep you compliant and protect user privacy choices.
The New Directives
On March 7, 2024, the CJEU ruled that TC Strings (which store user consent preferences) qualify as personal data. This means they must be protected to the same standards as other types of personal data.
As a result, a new consent category called "Special Purpose 3" has been introduced to further safeguard and manage user privacy choices.
New Compliance Requirements
- Special Purpose 3: This consent purpose enables participants in the TCF to have a legal basis for processing users’ privacy choices (the TC Strings), now classified as personal data. If your business sells advertising space through publisher sites, you’ll need to conduct and document a legitimate interest assessment (LIA) showing that users’ interests are not overridden by your legitimate business interests.
- Transparency and Clarity: User interfaces must now be fully transparent and clear—giving users all the information they need, including how long their consent will be stored. Any misleading or incorrect information must be avoided.
October 4, 2024 is the deadline for CMPs (Consent Management Platforms) to comply with the new requirements.
How My Agile Privacy is Preparing
Our team is proactively assessing and implementing all the necessary changes to ensure full compliance by the required deadlines.
We’ll keep you updated on any new developments and provide all the support you need for this transition—which will be automatic with a software update.
Thank you for your trust and cooperation!