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Understanding Your Consent Options Related To CIPA And Wiretapping Concerns

In Light Of Recent Legal Trends In California—Specifically The Rise In Claims Under The California Invasion Of Privacy Act (CIPA)—Publishers Are Increasingly Looking For Ways To Bolster Their Consent Disclosures. 

As an IAB-certified CMP, Admiral provides the tools to manage these risks. However, each approach carries different implications for your data signals and user journey. 

Below outlines the primary paths you can take.

Show Opt-Out Toggles on First Pageview

The most straightforward approach is to display the opt-out toggles on the first page view. 

 

Under Privacy & Consent, scroll down to Interaction. 

 

Enable the toggle for “Engage about consent on first page load.”

Enabling the toggle for “Engage about consent on first page load” will result in the toggles being open and displayed above the fold on the initial pageview. 

 

 

Show Welcome Message

To allow for a more customized message, you can deliver a “Welcome Message” from Copilot. This can be used to disclose the use of cookies or trackers, and notify visitors on how to opt out. 

 

This can be set up by going to Visitor Copilot and clicking on the Edit button near “Welcome Message.” 

 

 

Enabling the Welcome Message will result in a Nudge being displayed on the first page load. 

 

Visitor Action Disclosure

For situations where an affirmative action (such as a button click) is required, you can set up a Journey to display a disclosure message.

 

Use the configurations in the video below to set up a Visitor Action Disclosure message. This will require the visitor to click “Accept” before they can access your content. 

 

GeneralConsent.mov

 

Visitor Action Disclosure examples.

 

Gated Experience: 



Banner

 

Nudge



EU CMP

One drawback to all of the options above is that the visitor will be in an opt-in state by default. Each of the options above uses the IAB’s GPP framework and will signal to downstream vendors that the visitor is opted-in. Some publishers may choose to have an opt-out signal as the default. 

 

Currently, the way to achieve this is to target the EU CMP to visitors from California. From the Consent Journey, select Edit Targeting. This will display a peaking panel that lets you select California as the target region. 

 

 

   

 

Visitors from California will now see the EU CMP, and the IAB’s TCF signal will be set to opt-out by default. 

 

 

Warning about using both the EU CMP and the IAB’s GPP in California

It’s important to note that IAB GPP and IAB TCF are completely separate frameworks. It is possible that if you combine more than one of the approaches above, or use the EU CMP in California, there may be signal conflicts between GPP and TCF.

 

For example, if the visitor selects “Reject All” from the EU CMP, but does not opt out using the GPP toggles, IAB's TCF will signal opted-out, but IAB’s GPP will signal opted-in. 

 

To avoid this conflict, we recommend using a singular approach or use custom development to sync the two signals. You should consult with your legal counsel on the best approach for your organization before any implementation.