Practical recommendations

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To ensure compliance Campaign and Digital Intelligence Limited recommend review and consideration be taken to the below:

 

Cookie Banner - It is a requirement to inform the visitor to a website in a ‘clear and unambiguous way’ that Cookies are being used on the website. Under Article 6(1)(a) the existing generally accepted practice of continued browsing as “conduct which clearly indicates in this context the data subject's acceptance” will suffice as consent.

 

Cookie Statement - Should a compliance question or issue arise, additional scrutiny will be placed on contents of cookie policy/statements. The existence of such policy, clearly explaining the description and purpose of the cookies used will assist in proving reasonable care has been taken to obtain freely given, specific and, most importantly, informed consent.

There are several services that provide functionality to satisfy the requirement found in Article 7(3). To assist specifically, with the right to withdraw consent.


Legitimate Interest - If using the legitimate interest principle within your website tracking it is advisable to have on record during your GDPR preparation that this is the case. This should include the grounds on which you are using this.

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