Thanks for the pointers Renzo.
Shopping basket items in a cookie, words fail me. I dearly hope that's
dumbed down and not the result of an actual lack of understanding of what is
going on in the app.
They'd be better actually addressing the issue of authenticated sessions,
which would then give clarity to not only ecommerce but also any web site
which uses a cookie as a fundemental part of its authentication process.
Currently that reads to me like they're not at all clear how the cookies are
being used in the first place - which for me is fairly important when you're
telling people who run web site what they should be doing.
Ian
----- Original Message -----
From: "Marchini, Renzo" <[log in to unmask]>
To: "Ian Griffiths" <[log in to unmask]>
Cc: <[log in to unmask]>
Sent: Friday, June 01, 2012 1:42 PM
Subject: RE: [data-protection] Cookies; Subject Access
"strictly necessary" is very strictly interpreted - remembering sessions for
keeping track of the shopping basket, for example. look at page 12-13 of
ICO's recent guide to the rules....
R
Renzo Marchini
Counsel
Dechert LLP
+44 (0) 20 7184 7563 direct
+44 (0) 20 7184 7001 fax
[log in to unmask]
www.dechert.com
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Ian Griffiths
Sent: 01 June 2012 12:40
To: [log in to unmask]
Subject: Re: [data-protection] Cookies; Subject Access
'The one exception to these rules is if the website's use of the cookie is
"strictly necessary" for a service requested by a user.'
Anyone got more information on this? Quite a fundemental exemption.
----- Original Message -----
From: "Marchini, Renzo" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Friday, June 01, 2012 10:26 AM
Subject: [data-protection] Cookies; Subject Access
Subscribers might be interested in:
* a note on cookies we produced to coincide with this week's change.
(Are you all compliant? I think Dechert is (implied consent, don't you
know!).)
http://www.dechert.com/files/Publication/6cd4e280-2e98-4c9a-868f-7e33dc3895cb/Presentation/PublicationAttachment/453bbd62-00fb-4f8a-8d76-c3d0bbb72b38/Data_Protection_and_Privacy_05-12_Cookies_Update.pdf
* an article on the Elliott SAR decision:
http://www.scl.org/site.aspx?i=ed26547
Renzo
Renzo Marchini
Counsel
Dechert LLP
+44 (0) 20 7184 7563 direct
+44 (0) 20 7184 7001 fax
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