Colloids Group: Cookies advice
Introduction
A scan of the three websites (Colloids, PMB and PW Hall) shows the following cookies are currently in use:
If this is the case in practice, the cookie compliance set out below does not need to be adhered to in full as there are no cookies used on two of the websites. The cookie notice and banner should be removed from the Colloids website as this could be misleading for users of the website as it suggests that cookies are in use. There should also be a statement in the privacy notice that there are no cookies used on the website in order to explain why there is no consent banner or cookie notice.
The Colloids Group should consider whether to expand its use of cookies in order to make the website a more useful resource for them. For example, a common use of cookies is in relation to collecting analytics about the website’s use. This can be beneficial to see which areas of the website are frequently used and how users move around the website.
Where cookies are used, this advice note provides comprehensive guidance regarding the compliance steps for the Colloids Group websites.
Overview of compliance requirements
Cookie compliance in the UK requires a number of different elements to be present on a website’s design, as set out below:
| Element | Compliance obligations | Colloids next steps |
| 1. Cookie banner | · Cookies which are not deemed strictly necessary (“non-essential cookies”) cannot be placed on a user’s device before you have obtained consent.
· This consent is usually obtained by using a cookie banner which is displayed on a user landing on the page. · Guidance from the ICO states that the options to “accept” or “reject” non-essential cookies need to be of equal weighting and prominence. |
· Use the PW Hall cookie banner across all Colloids websites that use cookies (see couple of suggested improvements to the banner below). |
| 2. Cookie settings | · Where different types of non-essential cookies are used, users of the website should be given choices as to what cookies they want to consent to.
· There should be a link to settings on the cookie banner. The settings should also be accessible to users at any time (not just the first time they enter the website). |
· Use functionality on PW Hall’s website across all Colloids websites including access to the cookie settings within the cookie notice. The settings should reflect the cookie types that are actually used in practice. |
| 3. Cookie notice | · Users of the website must be given “clear and comprehensive information” on cookies used on the website.
· The PW Hall cookie notice shows a good level of compliance with market standards of cookie notices. · PMB does not appear to have a cookie notice and the Colloids version is not as detailed as the one on the PW Hall website. |
· Use the PW Hall notice across all websites with the amendments, as shown below.
· Conduct a technical review of any cookies used in practice across each of the websites and decide whether any others would be useful to use. |
Compliance with each of these elements is reviewed on the following pages:
This is the cookie banner from PW Hall, which shows a good level of compliance with current laws and guidance.
Some notes for improvement:
We would advise adopting the two above changes in order to follow “best practice” however the current version is reasonably compliant with the guidance and laws.
The cookie settings on the PW Hall website can be found in two places:
(1) on the second layer of the pop-up when you select “view preferences”; or
(2) from within the cookie notice where there are sliders the user can adjust to give or revoke consent.
This is good practice and the same process should be adopted across all the websites.
The cookie settings should cover each of the categories of cookies used on the website (e.g., analytics/statistics, marketing, preference). There should be an option (usually a slider) to turn these “on” or “off” i.e. consent or not. These preferences then need to actually be respected in terms of the cookies placed on that user’s device.
A technical review of the cookies used on each website should be conducted and these categories then stated on the cookies settings tool (and in the relevant cookie notice).
Users need to be able to get back to the settings to revoke or grant consent after interacting with the initial cookie banner. Including these settings in the cookie notice is an effective solution to this so we recommend all websites adopting this.
WordPress Functional […] Retention timeframe: [ ]. First party cookie/third party cookie
Wordfence Functional […] Retention timeframe: [ ] First party cookie/third party cookie
WooCommerce Statistics […] Retention timeframe: [ ] First party cookie/third party cookie
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Miscellaneous Purpose pending investigation […] Retention timeframe: [ ] First party cookie/third party cookie
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