I guess it's no surprise that someone had to resurface this discussion. Sorry!
I wonder if anyone had seen an email circulating in the charity sector that mentions Cookie Control by Civic - http://www.civicuk.com/home . It’s an overlay that sits in a corner of your pages with a statement and links to your policy, but once users have accepted it, it doesn’t ask again (presumably by way of a cookie!). Take a look at http://beta.suffolk.gov.uk/ for a trial implementation. Whether it's through this, or using our own implementations, do people think that this is a valid approach that satisfies both the legislation, and the need to minimise any user impact? I have my own views, but I don't want to pre-empt the debate.
The email also gives a link to the BBC's cookie section http://www.bbc.co.uk/privacy/bbc-cookies-policy.shtml
For my part I am:
i) mid-way through a cookie audit of our site and sub-sites, which is proving far more wide-reaching and cumbersome than I ever imagined (and I have a good imagination!)
ii) wondering where the boundaries of our responsibilities go in terms of third-party hosted microsites for example our shop, ticket sales, online fund-raising etc. Most have our own branding and site design/navigation, and therefore any differentiation to the end user from our core site is (hopefully) transparent. And most but not all run from a sub-domain of kew.org. But to what extent might it be our legal responsibility, or the suppliers of those white-label sites?
iii) wrestling with the issue of what defines an 'essential cookie'
iv) discovering that even the definition of what a cookie is can be somewhat blurred (e.g. sessionids)
Anyone care to chip in with some sage advice?
Thanks, James
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James Morley [log in to unmask]
Website Manager Tel. +44 (0)20 8332 5759
Royal Botanic Gardens, Kew www.kew.org
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________________________________________
From: Museums Computer Group [[log in to unmask]] On Behalf Of Diana Erskine [[log in to unmask]]
Sent: 25 January 2012 09:31
To: [log in to unmask]
Subject: Re: Cookies legislation: what are you doing?
Hi all,
I don't know if this helps....
I am a Project Manager working at an agency who have actually been working with the ICO to apply their own guidance to their own website :-)
Its been an interesting project and with full analytics in place there have been some very interesting findings - the drop out of people on the homepage was higher than anticipated. As such we are currently working on some solutions which alert people 'nicely' to the use of cookies.
We're actually doing a lunchtime seminar with the ICO speaking and with our findings and recommendations on the 24th February in Manchester. If anyone is interested email me on [log in to unmask] and I'll get you a place :-)
Kindest regards,
Diana
-----Original Message-----
From: Museums Computer Group [mailto:[log in to unmask]] On Behalf Of Matthew Cock
Sent: Wednesday, January 25, 2012 8:52 AM
To: [log in to unmask]
Subject: Re: Cookies legislation: what are you doing?
Thanks John. Precisely.And I assume that you are waiting until May 25 until you decide exactly what Tate's appetite for risk is?
Matthew
Head of Web | Department of Learning and Audiences | The British Museum | www.britishmuseum.org
Sent from Blackberry: 07971433841
----- Original Message -----
From: Museums Computer Group <[log in to unmask]>
To: [log in to unmask] <[log in to unmask]>
Sent: Tue Jan 24 20:25:48 2012
Subject: Re: Cookies legislation: what are you doing?
Hello
It's really about individual organisation's appetite for risk. The latest guidance from the ICO (pdf at http://bit.ly/sMSUvk ) specifically covers analytics cookies in the very last section. See below with my emphasis using *'s.
John
We only use analytical cookies - if nobody consents that will seriously restrict the amount of information we can get to improve and develop our website
The Regulations do not distinguish between cookies used for analytical activities and those used for other purposes. We do not consider analytical cookies fall within the 'strictly necessary' exception criteria. This means *in theory* websites need to tell people about analytical cookies and gain their consent.
*In practice* we would expect you to provide clear information to users about analytical cookies and take what steps you can to seek their agreement. This is likely to involve making the argument to show users why these cookies are useful. Although the Information Commissioner cannot *completely* exclude the possibility of formal action in any area, it is *highly unlikely* that priority for any formal action would be given to focusing on uses of cookies where there is a low level of intrusiveness and risk of harm to individuals. *Provided clear information* is given about their activities we are *highly unlikely* to prioritise first party cookies used only for analytical purposes in any consideration of regulatory action.
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