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IAB Europe TCF Action Plan approved...but not published

You may be forgiven for having forgotten all about the Belgian Data Protection Authority's decision regarding IAB Europe and the processing of personal data in the context of the Transparency and Consent Framework (TCF) which sent so many shock waves through the adtech industry back in early February last year. After the initial noise, very little was heard. [For a quick refresher on what this was all about, you can read our detailed summary of that decision here.]

For those who do remember the bumpy start to 2022, you may have wondered what happened to the required action plan? Well, in a press release this week, the Belgian DPA published a press release (included as an update at the end of the original 2 February 2022 release available here so you will need to scroll to the bottom to view) in which they announced that they have now approved the IAB's action plan. This may come as a bit of a surprise given the complexity of the issues and potential solutions and the fact that the decision itself is still subject to an appeal.

So what does the action plan say and what impact will it have? Well, alas, for that crucial detail we are kept waiting since apparently further details of the action plan can't be disclosed because of the pending court proceedings - i.e. IAB has had to come up with actions to implement rulings that are still disputed. All we do know is that IAB Europe now has a maximum of six months to implement the proposed measures that may not be required at all. Excellent.

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