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Google and TCF 2.0: how to collect consent for personalized ads

If you’re a publisher using Google services like Ad Manager, AdMob, and AdSense, you need to comply with Google’s EU Consent policy and collect explicit consent to ad personalization before displaying personalized ads to EU users.

As you can see below, when consent for ad personalization is not collected, Google will serve your EU users with non-personalized ads (or no ads at all) by default, impacting your ad revenue.

Google’s requirements

To meet Google’s requirements, you must allow users to consent to or reject processing for Google’s ad personalization.

One way to do this is to take advantage of the Transparency and Consent Framework v2.0: Google now fully supports TCF 2.0 and is included on the TCF global vendor lists.

If you’d rather not use the TCF but still need to handle personalized/non-personalized ad requests, please contact us.

Before listing Google’s requirements to serve personalized ads, we need to talk briefly about purpose and legal basis. According to TCF 2.0, advertising services (also known as vendors) like Google are allowed to process personal information based on 10 purposes:

  1. Store and/or access information on a device
  2. Select basic ads
  3. Create a personalized ads profile
  4. Select personalized ads
  5. Create a personalized content profile
  6. Select personalized content
  7. Measure ad performance
  8. Measure content performance
  9. Apply market research to generate audience insights
  10. Develop and improve products
TCF advertising tracking preferences - iubenda Cookie Solution

It’s also worth adding that, to process personal data, vendors can rely on two alternative legal bases: users’ consent or legitimate interest. As a publisher, you need to allow your users to freely give, deny, or withdraw their consent for Google’s ad personalization at any time.

Our Privacy Controls and Cookie Solution allows your users to customize their advertising tracking preferences and allows you to choose which purposes are presented to your users – disabling specific purposes entirely if needed. You can also determine the viable legal basis for certain purposes (consent and/or legitimate interest). More info in our complete guide to TCF 2.0.

Requirements to serve personalized ads

Google will serve personalized ads when all of the following criteria are met:

  • The end-user grants Google consent to:
    • Store and/or access information on a device (Purpose 1)
    • Create a personalized ads profile (Purpose 3)
    • Select personalized ads (Purpose 4)
  • Legitimate interest is established (or consent is granted, where a publisher configures their CMP to use publisher restrictions to request consent for Google) for Google to:
    • Select basic ads (Purpose 2)
    • Measure ad performance (Purpose 7)
    • Apply market research to generate audience insights (Purpose 9)
    • Develop and improve products (Purpose 10)

Requirements to serve non-personalized ads

If the requirements for personalized ads are not met, Google will serve non-personalized ads when all of the following criteria are met:

  • The end-user grants Google consent to:
    • Store and/or access information on a device (Purpose 1)
  • Legitimate interest (or consent, where a publisher configures their CMP to request it) is established for Google to:
    • Select basic ads (Purpose 2)
    • Measure ad performance (Purpose 7)
    • Apply market research to generate audience insights (Purpose 9)
    • Develop and improve products (Purpose 10)

If you don’t have consent for Purpose 1, Google will attempt to serve limited ads if you have legitimate interest or consent for Purposes 2, 7, 9, and 10.

Summing up:

Purposes Personalized ads Non-personalized ads Limited ads
1, 2, 3, 4, 7, 9, and 10
1, 2, 7, 9, and 10
2, 7, 9, and 10

If neither set of requirements above are met, Google will serve no ads.

Occasionally, some users may receive a message from Google stating that: “You are not disclosing all the third parties you work with, including the Ad Tech Providers (ATPs) and therefore you’re not compliant with Google’s policy”.

If you’ve received such a message, don’t panic, we’ll show you how you can fix this below.

The reason you might have received it is because, from a Google check, some of the Ad Technology Providers you selected during the setup of Google Ad Manager don’t appear to match the ones declared within your CMP.

If you run personalized ads on your website/app, within your Google Ad Manager / AdSense UI (Admin > EU User Consent page), you should have selected one of these options:

Google usually comes with a list of the ATPs that are found to be missing.

To fix the issue and be compliant with Google’s request you must therefore declare which third parties could measure and serve ads for EEA and UK users on your websites and apps (Ad Technology Provider Controls: Ad Manager Help CenterAdMob Help CenterAdSense Help Center) including all of them inside your Privacy and Cookie policy.

If you need help on how to add services to your Privacy and Cookie Policy check our guide.

❗️ By default, iubenda privacy policy generator doesn’t allow you to add more than 150 services. If you need to, please reach out to us and we’ll help you to get it done.

Lastly, you may also be requested to include this link about Google processing activities of users’ data. 
The link is automatically embedded inside the generated policy when you select any Google’s advertising services within our generator: 

  • Google DV360, 
  • Google Campaign Manager 360, 
  • Google Ads Similar audiences 
  • Google Ad Manager 
  • Google Ad Manager Audience Extension, 
  • Google Ads Remarketing, Google 
  • AdSense 

If you are requested to, and you have to show it to Google, you can find it inside complete view of your Privacy Policy, in the description of Google’s service under the “Detailed information on the processing of Personal Data” section, clicking on “Google’s partner policy”, as shown below:

google's partner policy

iubenda and TCF 2.0

 

Thanks to our support for TCF 2.0, our IAB registered Consent Management Platform (CMP) allows you to collect consent for Google’s ad personalization:

  1. Tick the Enable IAB Transparency and Consent Framework option in the Privacy Controls and Cookie Solution configurator (if you haven’t already activated the Privacy Controls and Cookie Solution, here’s a tutorial on how to get started).
  2. Paste the resulting Privacy Controls and Cookie Solution whitin the <head> section of your website’s HTML as the first element.
  3. Use one of the prior blocking methods supported by our Privacy Controls and Cookie Solution to directly block Google’s scripts and execute them only after consent has been collected.
How to comply with country-specific requirements

Different countries might have some specific requirements you may have to comply.
The Belgian Data Protection Authority (DPA) has recently issued a decision on IAB Europe and the Transparency and Consent Framework (TCF) setting out some additional requirements to provide enhanced transparency and more informed consent to users.

iubenda can help you meet the most stringent requirements, so if you operate with Belgium make sure you use this configuration.

Furthermore, some other national DPAs, like in Italy, have excluded the use of legitimate interest as a valid legal basis, and it’s important to restrict it to “Consent only” if you operate in those countries.

To make sure you set up the best configuration you can check the country-specific requirements in our Cookie Consent Cheatsheet.

For more information, please read our guide to iubenda’s CMP and IAB TCF 2.0 or view the demo of our Privacy Controls and Cookie Solution with TCF 2.0 enabled.

Additional Consent Mode

Our Privacy Controls and Cookie Solution also supports Google’s Additional Consent Mode, which allows you to gather consent for Google ad partners that are not yet part of the Transparency and Consent Framework but are on Google’s Ad Tech Providers (ATP) list.

Don’t confuse Additional Consent Mode with Consent Mode, a feature that allows you to manage cookies for advertising and analytics purposes.

To enable this feature, select the checkbox Support Google’s Additional Consent Mode, to gather consent for Google’s advertising partners that do not adhere to the TCF within the Privacy Controls and Cookie Solution configurator (in some cases the checkbox will be automatically selected when you enable the TCF for the first time):

This will add "googleAdditionalConsentMode": true to your code snippet:

<script type="text/javascript">
    var _iub = _iub || [];
    _iub.csConfiguration = {
        "lang": "en",
        "siteId": XXXXXX, //use your siteId
        "cookiePolicyId": YYYYYY, //use your cookiePolicyId
        "countryDetection": true,
        "consentOnContinuedBrowsing": false,
        "perPurposeConsent": true,
        "enableTcf": true,
        "googleAdditionalConsentMode": true,
        "banner": {
            "acceptButtonDisplay": true,
            "customizeButtonDisplay": true,
            "rejectButtonDisplay": true,
            "position": "float-top-center"
        }
    };
</script>
<script type="text/javascript" src="//cdn.iubenda.com/cs/tcf/stub-v2.js"></script>
<script type="text/javascript" src="//cdn.iubenda.com/cs/iubenda_cs.js" charset="UTF-8" async></script>

Fixes for common errors

Troubleshoot some of the most common TCF 2.0 errors across Ad Manager, AdSense, and AdMob by taking the following actions:

Error Description Suggested action to take (if any)

1.1

Caused by user action. Error 1.1 occurs if the user doesn’t give consent to Google’s ads. This means that almost any website will get at least some 1.1 errors.

This error is perfectly normal as long as the number of occurrences is in line with the number of users choosing “Reject” on the cookie notice (if implemented), or disabling ad tracking manually through the TCF preferences. This error, therefore, should only cause concern if it’s abnormally high.

2.1

Related to the configuration of the TCF on the site for the consent to personalize ads.

Google doesn’t serve ads, not even non-personalized ads, if the user has not expressed a preference in regards to cookies or has not given consent. To solve this problem, you must only run the Google script when you have gained consent.

We support two main implementation methods for our Privacy Controls and Cookie Solution. If you work with Google ads and you’re getting this error, you must mandatorily block Google’s scripts prior to collecting consent using one of the methods listed here.

Alternatively, the error could be due to an incorrect cmpStatus sent by the CMP.

4.1

It occurs when the TC string being generated is using a version of the Global Vendor List (GVL) that doesn’t include Google, because it was collected pre-August 1st, 2020 (i.e before Google joined the GVL).

Modify your CMP configuration to ensure consent collected prior to August 1st is invalidated. In the Privacy Controls and Cookie Solution, this can be done by setting "invalidateConsentBefore": "2020-08-01" using this method.

5.2

Google doesn’t allow to share consent with other sites, as consent has to be service-specific.

Our Privacy Controls and Cookie Solution no longer saves global consent, so there’s no need for any adjustments on your part.

6.1

Consent served is v1 and not v2. This can happen when using AMP because of the cache (keep in mind that errors are per ad unit and are cumulative over the last 7 days).

Update your AMP pages in order to use the new consentRequired and checkConsentHref parameters as specified in our guide.

See also