COOKIE POLICY

Cookies can help provide a unique and tailored user experience. But what are the different types of cookies? What are they used for? Can they be deleted or blocked? Read this guide to find out more about cookies and how they affect you

What are cookies? Cookies are small text files placed on a user’s computer (or smartphone), which are commonly used to collect personal data. Most website operators place cookies on the browser or hard drive of their user's computer. Cookies can gather information about the use of a website or enable the website to recognise the user as an existing customer when they return to the website at a later date. This file is neither a virus nor spyware. The law protects website users and lets them opt-out from the use of cookies on their website browser.

Benefits of cookies? Cookies are used to make the user's web experience faster, convenient and personalised. For example, you can select a language to view a website the first time you visit it. When you visit the website again it will save your preference.

Types of cookies:

Session cookies: Session cookies, also known as 'temporary cookies', help websites recognise users and the information provided when they navigate through a website. Session cookies only retain information about a user's activities for as long as they are on the website. Once the web browser is closed, the cookies are deleted. These are commonly used on shopping websites or e-commerce websites.

Permanent cookies: Permanent cookies, also known as 'persistent cookies', remain in operation even after the web browser has closed. For example, they can remember login details and passwords so web users don't need to re-enter them every time they use a site. The law states that permanent cookies must be deleted after 12 months.

Third-party cookies: Third-party cookies are installed by third parties with the aim of collecting certain information from web users to carry out research into, for example, behaviour, demographics or spending habits. They are commonly used by advertisers who want to ensure that products and services are marketed towards the right target audience.

Flash cookies:

Flash cookies, also known as 'super cookies', are independent of the web browser. They are designed to be permanently stored on a user's computer. These types of cookies remain on a user's device even after all cookies have been deleted from their web browser.

Zombie cookies: Zombie cookies are a type of flash cookie that is automatically re-created after a user has deleted them. This means they are difficult to detect or manage. They are often used in online games to prevent users from cheating but have also been used to install malicious software onto a user's device.

Law on cookies: To comply with UK and EU regulations governing cookies under the GDPR and the ePrivacy Directive you must show and implement the following: 

  1. Receive users’ consent before you use any cookies except strictly necessary cookies.

  2. Provide accurate and specific information about the data each cookie tracks and its purpose in plain language before consent is received.

  3. Document and store consent received from users.

  4. Allow users to access your service even if they refuse to allow the use of certain cookies

  5. Make it as easy for users to withdraw their consent as it was for them to give their consent in the first place.

Further information can be found on the following Governmental links. https://ico.org.uk/for-organisations/guide-to-pecr/guidance-on-the-use-of-cookies-and-similar-technologies/

https://gdpr.eu/cookies/

Please note that the US does not have a current GDPR system in place, and do not require consent for cookies. They do however have a federal law that places strict restrictions on the use of cookies - the Children's Online Privacy Protection Act (COPPA)

 https://www.ftc.gov/site-information/privacy-policy/internet-cookies

What counts as consent? Consent must be freely given, specific and informed. It must involve some form of unambiguous positive action, for example by ticking a box or clicking a link. The user must fully understand that they are giving consent. Therefore, consent cannot be given if the information is only provided as part of a privacy policy that is hard to find, difficult to understand, or rarely read. Consent does not necessarily have to be explicit consent. However, consent must be given by a clear positive action. Users must fully understand that their actions will result in specific cookies being set, and have taken a clear and deliberate action to give consent. This must be more than simply continuing to use the website. To ensure that consent is freely given, users should be able to disable cookies.

Can cookies be erased or blocked?  Most cookies can be erased or blocked. To erase cookies you will need to find the folder or file where they are stored on your device and delete them. Session cookies will automatically be deleted when you close your web browser. You can also block a website's cookies. You can do this by configuring your browser settings. You can also use specialist software that protects against malicious cookies. These applications can be customised to let you change the content of the cookies you want to receive or will allow being stored on your device.

Enforcement and penalties: The Information Commissioner's Office (ICO) is responsible for ensuring organisations comply with the law on cookies. They take a practical and proportionate approach to enforcing the rules on cookies. Where a business fails or refuses to comply with the rules, the ICO can take specific action as described below.

Information notices: The ICO can submit information notices which require organisations to provide the ICO with specific information within a certain time period.

Undertakings: Undertakings force organisations to take a particular course of action in order to improve their compliance.

Enforcement notices: Enforcement notices compel an organisation to take action specified in the notice. For example, a notice may be served to compel an organisation to start gaining consent for cookies. Failure to comply with an enforcement notice can be a criminal offence.