EU law requires organisations placing cookies through websites onto visitors’ computers to obtain their “consent” after providing clear and comprehensive information about how cookies are used on the websites.
In order to comply with this, we have taken four steps:
- Identified cookies and other tracking technologies served through this website, the purposes they fulfill, and related information such as their expiry and whether they are first or third party cookies.
- Assessed the intrusiveness of these cookies on visitors’ expectations of Privacy, based on the information collected in (i) above.
- Provided ‘clear and comprehensive’ information about website cookies with the appropriate level of disclosure corresponding with the intrusiveness of each cookie (See Cookie Settings Panel).
- Used an appropriate strategy for obtaining consent for website cookies, taking into account their use and intrusiveness. Certain types of cookie may qualify for legal exemptions and, where this is the case, consent will not be required for these cookies.
- who serves the cookie (i.e. a first or third party)
- what data the cookie collects
- what purposes it fulfils
- how long it endures
- nature of the website through which it is served.
For cookies requiring consent, we follow a three-tiered approach:
- for cookies of medium intrusiveness: we use the same strategy as for low intrusiveness cookies and also make contextual disclosures about cookie use at appropriate points on the websites (e.g. making cookie disclosures around targeted adverts or other website functionality relies on these cookies)
- for cookies of high intrusiveness: we implement a prior consent strategy (for example, the use of a banner / pop-up requiring visitors to consent to these cookies before they are served).
Cookie disclosures by type, rather than by identity: Given the substantial number of Cookies served through websites, cookies are grouped by category (for example, ‘advertising cookies’, ‘analytics cookies’). This enables cookie disclosures that are simpler and clearer for consumers to understand.