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Comment on lines +214 to +217
- purpose ID 0 restriction type 1
- purpose ID 0 restriction type 0
- specific purpose ID restriction type 1
- specific purpose ID restriction type 0
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Given we are in the descriptive segment it does seem hard to read as written (how would I know what a purpose 0 restriction is)

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- purpose ID 0 restriction type 1
- purpose ID 0 restriction type 0
- specific purpose ID restriction type 1
- specific purpose ID restriction type 0
- general restriction type 1 (require consent)
- general restriction type 0 (not allowed)
- specific purpose restriction type 1 (require consent)
- specific purpose restriction type 0 (not allowed)

For example if the TC String includes 1) a restriction signal that specifies consent is applicable to the vendor for the processing for a specific purpose and 2) a restriction signal that disallows the vendor the processing for a specific purpose, the vendor must consider it is not allowed to engage in processing for this specific purpose irrespective of the consent signal.

If the TC String includes 1) a restriction signal that specifies consent is applicable to the vendor for the processing for a specific purpose and 2) a restriction signal that disallows the vendor the processing for the same purpose, the vendor must consider it is not allowed to engage in processing for this specific purpose irrespective of the consent signal. (pub restriction type 0 takes precedence over pub restriction type 1).

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As suggested by Julien, would be good to have an example where a generel restriction overrules a specific one.


In case a vendor has declared flexibility for a purpose and there is no legal basis restriction signal it must always apply the default legal basis under which the purpose was registered aside from being registered as flexible. That means if a vendor declared a purpose as legitimate interest and also declared that purpose as flexible it may not apply a "consent" signal without a legal basis restriction signal to require consent.

In case of conflicting publisher restrictions, vendors should respect the following hierarchy to determine if processing is permissible at all for a specific purpose or which legal basis is applicable (from lower priority to higher priority):
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We should add language that CMP should avoid conflicting signals, but we would want to define rules to deal with them

Suggested change
In case of conflicting publisher restrictions, vendors should respect the following hierarchy to determine if processing is permissible at all for a specific purpose or which legal basis is applicable (from lower priority to higher priority):
CMPs should avoid to define conflicting publisher restrictions, specifically w.r.t. multiple restrictions on a specific purpose. In case conflicting publisher restrictions are present, vendors should respect the following hierarchy to determine if processing is permissible at all for a specific purpose or which legal basis is applicable (from lower priority to higher priority):

The Vendor’s declared Purpose ID that the publisher has indicated
that they are overriding.
<br><br>
When the value of PurposeID is set to 0 and the value of RestrictionType is <code>1</code>, the publisher has indicated they are overriding all TCF purposes to require Consent, including Special Purposes. In such a case, both Special Purposes are allocated the <b>ID 24</b> in the <code>PurposesConsent</code> field.
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We should also add a hint on ID 24 in the PurposesConsent field description

@HeinzBaumann HeinzBaumann self-requested a review November 29, 2023 17:08
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This issue has been put on hold by the TCF Policy team for now, therefore this cannot be committed into master.
Once the TCF Policy team is picking this up again, we can review this again.

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7 participants