Cookie Banner Signoff
You’ve created your cookie banner, it’s ready to go live, but is it compliant? Here are some questions to help assess the risks.
Questions to Ask
- Is it fair?
- Is it transparent?
- Does it explain if you’re sharing data to other data controllers for their own purposes?
- Is data being shared with companies that the user might find distasteful, untrustworthy or undesirable?
- Does it follow a “Privacy by Default” and “Privacy by Design” approach?
- Would anyone be surprised or annoyed if you were to explain exactly what cookies, scripts and services are being enabled by default?
- Does it present the information in an even way, or is it trying to influence the user to perform a specific action?
- Which other organisations are taking your approach? Has this approach been promoted/criticised/enforced against by Data Protection Authorities?
- Would you feel comfortable having a DPA, a customer and the press scrutinising your approach?
- Do you accept that your approach is a temporary measure and will have to become more conservative in time?
Consent Tests
Is the consent you are requesting:
- Freely given?
- Specific?
- Informed?
- Unambiguous?
- Requiring a statement or clear affirmative action?
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