- WHAT IS A COOKIE?
A cookie is a piece of computer code that your website may insert in a browser so it recognises a returning user to your site. For more information you can read the ICO website section on cookies.
We like cookies because they speed up how sites we visit. As business owners we like cookies because it allows us to work out what is popular or selling on our online sites.
Cookies can do way more than that and can be used to do way more than that.
As individual data subjects, we all worry about what exactly is being shared without our knowledge or consent.
If you did not design or set up your site, it is possible your site is running cookies that you don’t even know about.
If you use cookies you must have a cookie policy that is easy to find and easy to understand.
We put a section right at the front of your data privacy policy for you to complete.
- HOW DO YOU NOW WHAT COOKIES YOUR SITE USES?
If your site is on https (and it should be!):
One way is to type the URL of your home page into your browser and go to your home page. When the secure button comes up in the left-hand side of the space where the URL is displaying click the word secure and it will show how many cookies are running on your site.
IF THE ANSWER IS NONE then all you need to fill in on your Cookie policy section is We don’t use cookies on our site. Keep a note of when you checked and what you got and make sure you revisit this from time to time as it is important to keep this statement up to date.
For the majority of sites this will not be the correct answer since you probably used caching cookies (to help the site load faster) at the very least.
If you do have cookies then you need to figure out what type of cookies. You may want to try this [www.iubenda.com/en/help/262-come-identificare-quali-cookie-sono-installati-dal-tuo-sitoapp]. These actually give you a clue what your cookies do. This is a lot more in ‘techie’ speak and you may need help from your web designer or another tech specialist to figure out what it all means. You can go on to generate (at a price) your cookie policy but you will need a degree in astrophysics to understand it (we tried!) and it is possible your customers will have no idea what it means. Plain English is always a good way to communicate and that is why we need to start collecting samples and examples.
If, like most website owners, you use cookies you will need to put in some wording that explains what they do and why and you must seek consent to store cookies on their device.
Your cookies policy will need to say/cover all of the items that are true.
Paraphrasing their definitions can give us an interesting way to look at cookies:
Session cookies – allow websites to link the actions of a user during a browser session. remembering what a user has put in their shopping basket as they browse around a site. These session cookies expire after a browser session so would not be stored longer term.
Persistent cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising
First and third-party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company.
- CONSENT AND COOKIE POP UPS
Most of us use cookies of some kind or another. If you do, you will need a ‘cookie pop-up’ on your site. This is a pop up that you will link to your data privacy and cookie policy (which is why the cookie part is near the top).
For:
- WordPress users here are some options
The important thing is that your visitors know what is going on when they visit your site and have a simple way to consent to cookie use or to opt out of it.
- EXAMPLE COOKIE WORDING
If you know what cookies are on your site, then you can start to think about suitable wording to put in your Data Privacy Policy (or if you prefer, to have a separate cookie policy to link to in your Data Privacy Policy).
The more types of cookies you use, the longer your cookie policy statement is going to have to be.
We will start a file in our group to collect cookie wording that seems clear and useful. If you find any sites you think have got it nailed, please add them.
They are copyright to other organisations, but they can give you inspiration.
We are not suggesting wording in detail for you as we don’t know what your cookies do! Here is one idea:
We use cookies (small bits of code that are sent to your pc) to:
- Speed up how quickly the site loads if you come back (caching)
- Analyse how popular our pages and posts are (analytics)
- Track the user journey from arriving on site to leaving – so we can see what is popular and what content is working
- Identify if our advertising and/or social media brought you to visit us
- See who goes to our shopping cart for the first time (and identify if there were problems at the checkout stage)
- Work out which sites are sending visitors to us
- Track purchases from affiliates so we can give them their commission
- Remember returning visitors and customers
If you turn off all cookies, some or all of our site may not perform properly. You can turn them off by using the settings in your browser.
For further guidance about cookies, see www.aboutcookies.org and www.allaboutcookies.org
The Information Commission has guidance on cookies which can be found here.
ICO’s samples can be used but they need simplification.
ICO’s sample from their guidance on cookies:
Our website uses four 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 the website which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies we use are ‘analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily. Read more about the individual analytical cookies we use and how to recognise them [link]
In example cookie statements given by the ICO on their privacy policy guidance, they also suggest wording like this (and the links) could be included:
For further guidance about cookies, see www.aboutcookies.org and www.allaboutcookies.org
- IN CONCLUSION
Your cookie policy is going to be a work in progress this year. Why not start with your analysis and then put up some simple wording and move on a modify it as we all learn more and find some great examples.