Digitally Thinking

The ICO’s new cookie banner is here

The ICO’s new cookie banner is here and they want us all to follow suit. New guidance issued by the ICO will significantly affect the way cookies are placed and managed, you can read the full guidance here.

We will be explaining this further in our blog in the very near future, but here is a little taster to wet your appetite and keep your hand out of the cookie jar.

Cookies – New ICO Guidance - So what do I need to do now?

  1. Organise – clearly and thoroughly go through each cookie and figure out what it does, whether it is actually “Strictly necessary” to make the website operate or not.
  2. If in doubt clear them out. If you aren’t sure about a particular cookie then you should treat it with caution and that probably means either getting consent before you place it or just deciding to remove them forever. 
  3. Explain – for each cookie you keep, you need to explain to people how and why it works and be transparent about where that data goes and who gets to use it and for what purpose. 
  4. Record Consent – keep records of cookie preferences (yes – place a cookie!) or create a system that defaults to the highest privacy option each time if you are only using session cookies. If you want to record the fact that someone has consented to the placement of non-essential cookies, like analytics, then keep a record of that consent in order to create an audit trail in the event of any dispute later on.
  5. Banners – update your banner to make sure it complies with the new regulations, make it persistent and obvious. Ask for and actually acquire consent for non-essential (e.g. analytics/advertising) cookies BEFORE you place them.
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