Changes include the requirement for an explicit opt-in for non-essential cookies and the fact that analytics cookies are not considered essential. In addition analytics tags can no longer fire on a landing page without prior user consent and methods using implied consent are no longer valid.
Cookie compliance will be an increasing priority for the ICO in future and companies should start working towards compliance now. Initial steps to consider include:
- conduct a cookie & tracking technology audit
- plan a migration to an explicit opt in mechanism
- consider the implications of the changes and methods to mitigate against data loss