Effective empowerment technology

Cookie Management

Effective empowerment technology

Delivering

transparency building trust and minimising

unnecessary risk

This is the story of cookie management. Together with our world-class automated audit and assessment technology, any journey toward cookie compliance will save time, reduce costs and deliver unrivalled accuracy.

Contents

We want you to know as much as we do

Our service is focused on the rapid deployment of audit, assessment, categorisation and policy delivery.

Don’t travel alone

1

Your cookie landscape – it’s an ever changing panorama

2

The challenges you face

4

Outsourcing is the right solution

6

Step 1 – Assess your web estate

8

This can all be set up and fully functional in hours and is supported by an ongoing automated service to keep policies accurate and up to date.

Step 2 – Analyse your site for every type of cookie

10

Step 3 – Publish the detail online

12

Implied consent and achieving consistency

14

Why do you need updates at all?

16

Ongoing management – business as usual

18

Client profiles – confidence from keeping great company

20

Partners and associations – creating an industry standard

22

Some thoughts and questions to consider

24

Control I Compliance I Confidence

Do not travel alone

“Whilst it is not for me to endorse any particular tool or service, I applaud this overall development which is bringing some genuine innovation”.

The issues surrounding compliance and privacy are complex . . .

. . . and if the territory is unfamiliar, it makes sense to have the industry experts travelling with you. Control I Compliance I Confidence

Neelie Kroes, Vice President of the European Commission talking about the solution offered by Cookie Reports.

Imagine a journey focused on mitigating risk, increasing visitor confidence and cultivating trust and transparency in your brand. This is an entirely different journey to ‘doing the minimum’ or adopting a ‘tick the compliance box’ option. We’d like to demonstrate the difference . . . Page 1

Your cookie landscape It’s an ever changing panorama

At the heart of our technology is empowerment – designed to put you firmly in control of your cookie landscape, provide assurance that compliance requirements are fully supported and give you confidence in what’s being deployed. Control I Compliance I Confidence

Privacy is likely to present the greatest transformation, and opportunity, that online operations will encounter in the next 2-3 years. Cookies are just the start of a journey, and those that lead with clarity and transparency will increase consumer trust and improve brand loyalty. The journey may appear complex, time consuming and costly, but our unique software and operating processes offers simplification, consistency and efficiency. Our solution is delivered through proven and scalable automation – regardless of website numbers, language or operating location. From initial estate profiling, automated site audits and results assessment through to ongoing policy management (BAU) we minimise disruption to the visitor journey and your business operations – ensuring that you retain control and remain confident at the same time. Page 3

You may recognise some of these challenges: 1 Finding all the sites within your web estate It isn’t easy if you are running a complex multi-site operation. Many of our clients are surprised to learn how many ‘hidden’ sites we find.

2 Assessing and categorising cookies This is an almost impossible task to do manually – and with some web estates

hosting tens of thousands of pages, it is a complex and very time consuming task.

Cookie Reports has been set up to provide a fast, simple and practical solution to the complex issues of cookie compliance.

3 Creating your own specific cookies policy The legislation is complex and demands that information about all your cookies is published and updated regularly.

4 Managing the process The management of cookie compliance requires detailed management protocols and is resource intensive.

5 Getting this done in time The longer you leave it the greater the risk. Compliance legislation is now a reality. Can you afford to wait and see?

We call this activity ‘Managing your cookie landscape’ . . . and it works. Control I Compliance I Confidence

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And the point of outsourcing would be? 1 Save time . . . and money From set-up to deployment this complex system can be live within a few days. 2 Accuracy We find more cookies than any other search technology. Then we model them against know standards. This in itself is a unique service.

So what’s the solution? Give the problem to someone else. In fact . . . give it to us. Our powerful SaaS platform has been designed to grow with the needs of privacy legislation keeping you firmly in control. Control I Compliance I Confidence

3 Accountability We have worked with legislators and government agencies throughout Europe to give you confidence in the policies you publish online.

4 Reporting consistency We put you in control of our hosted service and offer worldwide support through your own unique private portal.

5 Minimise ongoing support The fully automated service requires very little time to administer leaving you with time to concentrate on the big picture.

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2 1 Here’s how it all works. Firstly, we take all your registered domain names, product, service, brand and company names together with your trade marks, and we run them through our web estate assessment engine. Control I Compliance I Confidence

Step 1

We assess your web estate

1a

1b

1c

1d

Verifying your web estate

Running our web assessment engine

Consolidated management reports

Your corporate portal

We input all your known website names, your business names and your brand names.

Our unique assessment engine finds both the links and as many combinations of websites that are connected to your business – directly or indirectly.

We provide you with a complete web estate profile, which will give you a solid foundation on which you can build your compliance process and procedures.

Secure cloud based portal facility from where you can review and edit your web estate.

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3 2 1 Next, by reading the detail of every page, then viewing the pages within a web browser, we find more cookies more efficiently than any other method . . . up to 82% more. We do in hours what could take you weeks. Control I Compliance I Confidence

Step 2

We analyse your sites for every type of cookie

2a

2b

2c

2d

Estate results

Results run through our audit engine

Detailed cookie analysis output

Designing your privacy policy

Whether you choose to analyse a single domain or multiple domains, the process is the same. Individual results can be processed in a planned campaign.

Our powerful auditing engine is a ‘Google-like’ spider that will find up to 98% of all cookies deployed on your site.

Detailed analysis of cookies found including classification and risk assessment. This unique insights give you the facts to make informed privacy rating decisions.

Our privacy policy templates have been created in consultation with Europe’s foremost legal practices and governing bodies.

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3 2 1 By merging the data from the cookie report with the privacy policy template, we will provide you with a totally unique service. Finally, hosted through your own secure portal your detailed privacy policy is published. Control I Compliance I Confidence

Step 3

We publish your cookie status online

3a

3b

3c

3d

Merging the data into your policy

Automated distribution to site managers

Select and confirm

Your final hosted privacy policy

We finally populate your personalised privacy policy with up to date cookie information making it the most complete product available today.

Unique links and details sent directly to site managers providing centrally agreed content to ensure that standards are adhered to.

Site mangers simply confirm ‘privacy’, elect a predefined cookie ‘categorisation’ and update ‘description’ as required.

The completed policy can now be published and either be hosted by us, or added to your site. We can simply supply ‘content’ or give you the code for your own pages.

Page 13

Implied consent

Apdopting a consistent industry-wide approach

A clear and unambiguous navigation to your cookie policy on every page of your site is an essential element of the journey.

We have worked closely with a number of major industry membership bodies and some of the worlds most recognised brands to develop, and agree upon, a consistent and recognisable navigation widget to help promote visitor confidence and trust in respect to their online privacy. Produced in your own brand colours as required, these widget-style links are anchored to the bottom right hand corner of the browser window. They will now appear on every page and can direct your visitors straight to your new and reassuring cookie policy page. This vital and unique element to our solution also works across mobile platforms.

This is how you can move towards implied consent . . . and build site visitor trust. Websites


Mobiles

Page 15

Why do you need updates at all? 1 Legislation demands it Whilst a one-off report and a brand new cookies policy get you off to a great start, it will quickly become out of date and therefore non compliant.

2 Your cookie landscape is an ever-changing entity How much control do you really have over what cookies are set across your web estate – and where they will appear?

However, this is not the end of the journey. It’s just the start of business as usual. Regular monitoring and updating of your policy are all taken care of with our Active Policy Plan.

3 It’s sensible business practise Consistency and accuracy are essential – both are achieved with our unique capability.

4 Cookies can cause other problems Although compliance is the main outcome from Cookie Reports, data

theft and performance are serious by-products from our interventions.

5 It’s the cost effective option Automating the process is cost effective, efficient, consistent and requires little ongoing management.

It couldn’t be any easier. Control I Compliance I Confidence

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Business as usual

Retaining control and managing your cookie landscape

After having put your cookie ‘house-in-order’ you will need a programme of essential ‘cookie housekeeping’. Regular monthly monitoring will alert you to any new cookies and report the changes. Control I Compliance I Confidence

Automated monthly audit runs

Comparison engine reviews audit

Report on changes what updates needed

Managers advised and policy updated

Each month all sites that come under the Active Policy Plan are again audited (code read and website operated in a browser) for all cookies, and a management summary together with a site owners reports will be created.

Results of the individual audits are analysed and reviewed against previous results. Comparison against your agreed (site by site, or estate wide) corporate ‘approved’ and ‘expected’ lists can be made.

Details of what has changed (what’s new and what’s been removed) are provided. Results can be either consolidated or distributed individually.

On a site by site basis, managers are advised of the changes (if any) and can quickly add details and publish an updated policy.

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[email protected]

Client profiles

We’ve been keeping great company

Our unique service is based on our experience of auditing thousands of sites across Europe. We fully understand the changing regulatory requirements in the EU, and by working closely with clients, suppliers and the enforcement bodies, we have been afforded a unique insight into the issues you will undoubtedly come across. This exposure has helped shape our platform, and whilst automation is at the heart of our service, we offer high levels of support to guide you on your journey through privacy management over the coming years.

Cookie Reports have been involved with some of the world’s largest brands.

“The overall service provided was excellent, with turnaround times that beat all expectations”.

Over the last 12 months we have been consulted by, and have acted on behalf of, many large corporate organisations. We have worked with international agencies and lawyers representing many European legislative bodies. We think you’ll be impressed with the company we have been keeping.

Barclays Bank, referring to the enterprise wide project of web estate and cookie audits across six divisions of Barclays.

We are now recognised key speakers across numerous events – and as consultants to a number of governments in Europe we are extremely well connected to the key names and industry bodies. This means we can offer exceptional levels of client confidence. By helping you make sense of how current issues can effect online operations, and by clearing up compliance ‘headaches’ and ‘improving brand value online’, our supportive privacy management service could all prove to be invaluable to you, and the organisation you represent. We look forward to travelling with you.


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[email protected]

Creating an industry standard Partners and associates

By working at an industry body level across the EU, and by listening to the issues and challenges that clients face, allows us to ensure our services remain at the forefront of innovation, whilst delivering ease of use and minimal manual intervention. We are also in the privilege position of being able to look at industry wide data and help support member bodies with the data and content they require to allow them to host objective governmental level discussions.

By forging partnerships with key organisations we are helping to set the standards.

“This is an essential service we are keen to support and promote to our members”. Client Services Head - ABC.

By forging partnerships with key organisations throughout Europe we are helping to set the standards that are rapidly becoming the focus for privacy initiatives adopted by many influential businesses. RIght now, these are just some of our friends. Membership bodies:

Our partners:

From event support and one-to-one members surgeries, our real life experience of service delivery allows us to offer your members and your clients ‘hands on’ and practical guidance – saving them time and money. Our partnership approach provides you with a unique and scalable platform to continuously address the issues that are changing the landscape of online communication. Whilst we hold an enviable position at the forefront of these developing technologies, we continual strive to improve our services by delivering innovation, providing relevant solutions and building trust within a fragmented industry.


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What’s really out there?

Getting the full picture of your cookie landscape

Oh- yes! Our recruitment site

Are those campaign sites still live?


Page 25

Must include mobile sites

Did we ever turn off the WAP site? Who owns all of these sites?


Page 27

Planning ahead

Building privacy into ‘business as usual’

Do we really need all these cookies????

Software and systems – what’s happening?

Who owns ‘apps’ data Our email marketing


Page 29

Ad servers – need better information

Who’s got access to our sites?

Mobile - sites, what are the options?

Of course – Facebook?? any other apps? Updating supplier contracts


Page 31

What are the touch-points?

Privacy management starts by considering every interaction

Kiosks

Websites

Mobile

Email


Page 33

Telephone Banners

Web forms

Registered users


Page 35

A few more things to consider Our clients are frequently asking these questions

How will we help our users understand the cookies on our sites?

How long will it take us to become compliant?


Do we already have a separate cookie privacy document?

What resources will we need to become compliant?

Page 37

Is inferred consent enough to comply? How do we link each page to our privacy document? . . . and do we need to? What is our long-term cookie strategy?

How will we regularly update our privacy document?


Page 39

What support do we need to implement our cookie strategy?

How will we help our users understand the cookies on our sites?

How will we cope with regular content changes?


Page 41

Disclaimer This document is offered as an overview and a starting point only – it should not be used as a single, sole authoritative guide. You should not consider this as legal guidance. The service provided by Cookie Reports Limited is based on an audit of the available areas of a website at a point in time. Sections of the site that are not open to public access or are not being served (possibly be due to site errors or downtime) may not be covered by our reports. Where matters of legal compliance are concerned you should always take independent advice from appropriately qualified individuals or firms. Copyright This material is proprietary to Cookie Reports Limited and has been furnished on a confidential and restricted basis. Cookie Reports Limited hereby expressly reserves all rights, without waiver, election or other limitation to the full extent permitted by law, in and to this material and the information contained therein. Any reproduction, use or display or other disclosure or dissemination, by any method now known or later developed, of this material or the information contained herein, in whole or in part, without the prior written consent of Cookie Reports Limited is strictly prohibited.


Cookie Reports Limited 1 Berkeley Street, London, W1J 8DJ United Kingdom +44 (0)20 7129 8113 [email protected] www.CookieReports.com