DPE-2026-0015

Biedverzoek naar veel partijen tegelijk

Een paginaweergave gaat tegelijk naar veel biedende partijen, elk met de context en een identifier.

Familie
Keten
Status
actief
Geldt voor
web, mobile-app

Wat er gebeurt

An advertising slot is auctioned in the moment the page or screen loads. To collect bids, the request is sent out in parallel to a set of bidding parties, each copy carrying the same material: what is being viewed, an identifier for the device or the person, and usually coarse location and device characteristics. Losing bidders receive the same copy as the winner and keep it.

Waarom het ertoe doet

The person sees one advertisement and does not see that the occasion for it was distributed to dozens of companies, most of which they will never encounter. What is being viewed can itself be sensitive: a page about a diagnosis, a debt, a lawyer. Once broadcast, the copy cannot be recalled, and the number of holders makes any later exercise of rights impractical.

Veelvoorkomende oorzaken

  • header bidding configured with a long list of bidders, each added without a separate assessment
  • an exchange forwarding the request onward to further partners after receiving it
  • the same identifier passed to every bidder, so the copies are joinable across recipients

Dit is het níet

A single third-party resource loaded from one party is Third-party resource loading. What distinguishes this entry is multiplicity: the same view, with the same identifier, delivered to many parties in one load. It is also not Undisclosed recipient, which is about a gap in a document; here the fault stands even if every bidder is named. The sync requests that usually follow an auction are Identifier synchronisation between parties. That entry is about two parties exchanging each other's value; this one is about one view reaching many. They occur together and are cited together, but a party can cap its bidder list without stopping the exchange, and stop the exchange without capping the list.

Hoe je het vaststelt

Indicator

Within one page or screen load, requests to hosts under four or more distinct registrable domains that each carry the same identifier value together with the address or title of what is being viewed. Two or three recipients is ordinary onward disclosure and belongs under the entries for the individual recipients; the finding here is the multiplicity, and the count of distinct receiving domains is what has to be reported. Four is a threshold set for this catalogue and not derived from a published source: below it the recipients can still be named one by one, above it the number is the point. Report the observed count as well, so a reader who holds a different threshold can apply it. In an application the same finding takes the form of one auction request whose body carries the device advertising identifier, coarse location and network operator in a single payload.

Methode

network-with-identifier

Kwaliteit van de detectie

90 van 100

De grenzen van deze bevinding

Wat dit patroon zou weerleggen

  • The identifier differs per recipient and no shared value connects the copies.machinaal te toetsende bevinding wordt zwakkerStill a broadcast of the context, but the copies are not trivially joinable.
  • The requests are made server-side and the observed hosts are one intermediary, not the bidders.met de hand te toetsende bevinding krijgt een ander patroonA server-side auction is not visible from the client. The finding then concerns the one recipient that is observable, and the onward set has to be established from the party's own documentation.
  • The capture shows only the accepted state, and refusing yields no such requests.machinaal te toetsende bevinding wordt zwakkerWith consent registered first this is a different discussion; the broadcast itself remains the fault, the consent question does not.
  • The requests carry no identifier and no address of what is being viewed.machinaal te toetsende bevinding vervalt

Wat dit patroon níet vaststelt

  • harm; the catalogue standardises a finding so it can be referred to, it does not weigh it
  • severity; there is no score here, by design. Weighing belongs to whoever applies the entry to a concrete case
  • unlawfulness; that is for a supervisory authority or a court
  • intent; a fault is usually a build decision, not a plan
  • absence: not finding it in one capture is not evidence that it is not there
  • participation; a party authorised in a declaration file is not thereby a party that received anything. Only an observed request establishes that
  • completeness; a browser or device capture sees the first recipient. What that recipient forwards onward is not visible from it, so any count is a lower bound

Reproduceren

  • manualMETHOD.mdno dedicated reproduction exists yet; follow the general method and the indicator above

Juridisch kader

Bepalingen

eu-gdpr-6-1-aeu-gdpr-5-1-ceu-gdpr-26

Veelgehoorde tegenwerpingen

The bid request is anonymous.

It carries an identifier that is stable enough to bid against, which is the entire point of sending it. A value that lets a party recognise the same device tomorrow is not anonymous.

Consent was collected in the consent framework.

Test what the person was actually told: how many recipients, named or as a list behind a link, and whether refusing removes them. A framework signal travelling alongside the request says nothing about whether the choice was informed or effective.

Losing bidders discard the data.

That is a statement about their internal handling, not something the sender can demonstrate. The sending is measurable, the discarding is not.

Geldt wanneer

to-processing

Aangetroffen in

De onderzoeken waarin dit patroon gemeten is.

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