Does TCF forbid “continuing to scroll” as consent?

No. No exact definition or guideline can be found in the guidelines of TCF detailing how user consent (e.g. explicit or implicit) is to be obtained. By implication, publishers therefore have the option to regard “continuing to scroll” as user consent.

Important: Various courts have busied themselves with the matter of “continuing to scroll” in the past. The main consensus: “Continuing to scroll” can NOT be regarded as valid user consent. Furthermore, the European Data Protection Board (EDPB) has already issued statements on this matter in its Guidelines from May 2020 and likewise classed “continuing to scroll” as a non-compliant means of obtaining user consent with respect to GDPR. Publishers contemplating this option anyway are advised to consult their lawyers or legal departments.

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