Cristiana Santos and Victor Morel: The problem with CMPs and TCF-based cookie paywalls

Cristiana Santos is Assistant Professor in Privacy and Data Protection Law at Utrecht University, holding a joint international Doctoral Degree in Law, Science and Technology from the University of Bologna, and a Ph.D. in Computer Science from the University of Luxembourg. She is an expert of the Data Protection Unit at the Council of Europe; expert for the implementation of the EDPB's Support Pool of Experts; and expert of the Digital Persuasion or Manipulation Expert Group. She holds an International Chair Starting Career position at the National Institute for Research in Digital Science and Technology (INRIA, 2023-2026) to work on technical and legal aspects of data protection. Prior to joining academia, Cristiana was a lawyer and worked as a legal adviser and lecturer at the Portuguese Consumer Protection Organization.

Victor Morel holds a Ph.D in Computer Science from INRIA and works at the Security & Privacy Lab of Chalmers University in Gothenburg (Sweden). He is working on usable privacy for IoT applications, and his interests encompass privacy, data protection, networks security, usability and Human-Computer Interactions, applied cryptography, and the broad spectrum of ethics in technology. He is also a member of FELINN’s collegiate council, a French association (1901) defending decentralization, privacy, and free software through popular education.

Cristiana and Victor have co-authored a recent paper titled “Legitimate Interest is the New Consent – Large-Scale Measurement and Legal Compliance of IAB Europe TCF Paywalls”. With them we are directing our attention to consent walls in the context of publishers and the open market, having already dedicated two recent interviews to the “consent or pay” model as it concerns Instagram and Facebook (ie. Meta). We will also try to understand the challenges and potential conflicts of interest faced by CMP (Consent Management Platform) vendors.

References:

• Cristiana Santos at Utrecht University
• Victor Morel’s bio and projects
• Legitimate Interest is the New Consent – Large-Scale Measurement and Legal Compliance of IAB Europe TCF Paywalls (Cristiana Santos, Victor Morel, Viktor Fredholm, Adam Thunberg, 20/9/2023)
• Upcoming Workshop on Privacy in the Electronic Society - with Victor Morel (Copenhagen, November 26th 2023)
• EDPB: Report of the work undertaken by the Cookie Banner Taskforce
• CJEU to consider questions from IAB Europe TCF decision (Techcrunch)
• German court bans LinkedIn from ignoring “Do Not Track” signals (Townflex)
• Your Consent Is Worth 75 Euros A Year -- Measurement and Lawfulness of Cookie Paywalls (20/9/2022)
• IAB TCF 2.2 specification