[Part 4 of 5 / Table of Contents]

Recommended next steps

Given the lack of specific guidelines on the implementation of the new legislation we recommend undertaking the following steps:

1. Undertake an initial audit of your site and the way cookies are being used. The audit should classify the individual cookies based on the role they currently play – from “strictly necessary” to “not necessary”. The audit should also aim to define how third party cookies and partners are approaching the new regulations.

2. Review your site privacy and terms of use to ensure details are provided about how cookies are being used. Your site cookie policy should accurately describe how you use your customers’ data as well as the data practices on your site, including your use of analytics software and your advertising practices. Furthermore, the policy should include links to cookie advisory sites such as www.allaboutcookies.org.

The privacy and cookie usage policy adopted by the BBC is one of the most comprehensive – including a detailed description of all cookies used and for what purpose. http://www.bbc.co.uk/privacy/bbc-cookies-policy.shtml. British Airways has actually included a stand-alone “View our cookie policy” link on their global landing page instead of simply adding the cookie usage information within their legal information section.

That’s what happened with the Information Commissioner’s Office (ICO) implemented the new law with existing technology, over 90% of site visitors declined to accept a Google Analytics cookie, thereby disappearing from their analytics.

3. Involve your legal council to ensure there is a common view within your organization.

Every organization needs to ensure they are doing everything they can to get the right information to users and that they are allowing users to make informed choices about what is stored on their device. Not taking action is not a choice. Every organization affected by this legislation must demonstrate that it is taking specific steps to comply with the new requirements on user consent.

If a complaint about a website is received by the ICO they are likely to take a negative view of an organization that cannot show that it is taking steps to change current practice to bring about compliance with the new laws.

How we can help

In response to the legislation and the needs of our clients, we have developed a Cookie Audit solution which provides organizations with an audit of the cookies on their site. The audit will provide the following deliverables:

1. List and categorize all cookies being served across a specific site including a) first party cookies and b) third party cookies.

a) First Party cookies
b) Third party cookies:

i) Analytics (e.g. Google Analytics)
ii) Ad-Server (e.g. Doubleclick, CheetahMail, Commission Junction)
iii) Advertising (e.g. Specific Media)
iv) eCommerce
v) Surveys
vi) Blogs
vii) Widgets
viii) Server Functions

2. Identify the specific data points captured by first party and third party providers including ad networks and media publishers.

3. Define the impact on the current Digital Marketing practices resulting from a possible low level of user consent on specific cookies

4. Present findings and recommendations on an MS Word brief.

The cookie audit has a one-off cost of £4,950 and takes 10 working days from the day of sign-off. If you are interested in discussing the contents of this document further, please contact Alain Portmann, Head of Strategy at 0207 253 4133 or by email: alain [at] webliquidgroup [dot] com.

[Click here for Part 5 of 'The future use of cookies in the UK: From informing to obtaining consent']

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• Background
• What is the role of cookies?
• What is the new legislation on cookies in the UK?
• When is the legislation on cookies coming into effect?
• What should you do?
• Our view on the UK cookie legislation
• The different forms for obtaining consent
• Recommended next steps
• How we can help
• References & Sources

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About Alain Portmann

My job is simple. To inspire staff, clients and consumers.

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