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Proposed update to PBS GDPR restriction processing #1748

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bretg opened this issue Mar 10, 2021 · 3 comments
Closed

Proposed update to PBS GDPR restriction processing #1748

bretg opened this issue Mar 10, 2021 · 3 comments
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@bretg
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bretg commented Mar 10, 2021

Xandr has suggested that there's a detail in the original Prebid Server GDPR enforcement that needs to be revisited.

The suggestion is summarized in the "Full Enforcement" truth table in the appendix of https://docs.google.com/document/d/1fBRaodKifv1pYsWY3ia-9K96VHUjd8kKvxZlOsozm8E/edit#

Basically, we think the IAB's document is self-contradictory on this point:

On one hand it says:

RestrictionType 1 Require Consent (if Vendor has declared the Purpose IDs
legal basis as Legitimate Interest and flexible)

But then right next to that it says

If this value is 1 and vendor is registered under Legitimate Interest for that Purpose
then the vendor should not process for that Purpose.

The original PBS+GDPR spec implemented the intent of the first statement. The proposed revision focuses on the second statement, with the proposed changes in green:

Screen Shot 2021-03-10 at 11 06 05 AM

Screen Shot 2021-03-10 at 11 06 11 AM

Community input welcome.

@bretg
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bretg commented Mar 12, 2021

Confirmed with Prebid's privacy lawyers that this proposal is a good reading of the IAB's document.

I've updated Prebid's doc with the rule change here and will open a ticket for the change in PBS-Java

@SyntaxNode
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@bretg Is this complete in PBS-Java? Looks like it was already merged in.

@bretg
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bretg commented May 26, 2021

Released with PBS-Java 1.61

@bretg bretg closed this as completed May 26, 2021
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