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Cookie Policy and Consent Wording

Background Guidance

Under The General Data Protection Regulation (GDPR) (EU) 2016/679 the data collected by Cookies will almost always qualify as Personal Data. You must therefore provide certain information to the data subject about your use of cookies in your privacy policy, cookie policy and in your consent wording.

Currently most organisations rely on consent (either implied or opt-out) for the basis on which they can use cookies, but this will be much more difficult to rely on under the GDPR.

This is because under the GDPR implied consent is no longer sufficient. Consent must be given through a clear affirmative action, such as clicking an opt-in box or choosing settings or preferences on a settings menu. Simply visiting a site doesn’t count as consent.

Data subjects also have the right to reject your processing of their data and so you must make it possible to either accept or reject cookies. It must be as easy to withdraw consent as it is to give it. If you ask for consent through opt-in boxes in a settings menu, users must always be able to return to that menu to adjust their preferences and opt-out.

You will therefore need to update the way in which you obtain consent for using cookies and amend your Cookie policy.  

Consent Wording

We would suggest using the wording below. This should be clearly visible on the first page the website visitor lands on and must be provided to and clicked on by the website visitor before any non-essential cookies are collected. You should also provide with it a link to your cookie policy.

Proposed wording

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Some cookies are essential for our website to function properly, but these will not store your personal data. We would also like to use other cookies that may store your personal data.

By Pressing ‘OK’, you agree to our use of cookies as outlined in our cookie policy [link to cookie policy].

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