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ARTICLE · 20 JANUARY 2020

Cookies Consent: CNIL Steps In With A Proposal For Compliance

Mayer Brown
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On January 14, the French data protection authority (the "CNIL") released a proposal for a set of practical requirements for placing cookies in web-based and mobile application environments...

European UnionPrivacy
Diletta De Cicco
Diletta De Cicco
Charles-Albert Helleputte
Charles-Albert Helleputte
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On January 14, the French data protection authority (the "CNIL") released a proposal for a set of practical requirements for placing cookies in web-based and mobile application environments (the "Recommendations").

The Recommendations1 follow the CNIL's publication in July 2019 of guidelines summarizing the applicable cookies framework and its later consultation with stakeholders in the fall. The Recommendations are open to public consultation until February 25, 2020. Interested parties can vote on or contribute feedback on the Recommendations on the CNIL website.  

Here is a summary of the ingredients in the Recommendations' "recipe" for compliance:

  • To start with, use good flour, i.e., a cookies management tool.  The tool should be deployed on websites and mobile applications in a manner that will collect a valid consent. This is stating the obvious. However, getting the main ingredient right is not always that easy, especially for the privacy aspects of

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