COMPLIANCE
Cookie Consent Audit
Audit of cookie banners, preference center, and tracking technologies for compliance with the ePrivacy Directive and the GDPR consent standard.
Tasks in this template
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1
Scan the site and build an inventory of cookies and similar technologies D+1
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2
Classify cookies (strictly necessary, functional, analytics, marketing) D+3
Only strictly necessary cookies may be set without prior consent (ePrivacy Art. 5(3)). All others require informed, specific, freely given consent.
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3
Map purposes, legal bases, retention periods, and third-party recipients D+4
EDPB Guidelines 05/2020: consent must be as easy to withdraw as to give. Pre-ticked boxes are not valid consent.
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4
Review the cookie banner wording against IAB TCF and national DPA guidance D+5
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5
Test reject-all is equally prominent and one-click D+6
CNIL, Garante, and BfDI guidance: reject-all must be available on the first layer and as easy as accept-all. Dark patterns are not compliant.
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6
Verify no non-essential cookies are set before user consent D+7
ePrivacy Art. 5(3): storage or access to information on terminal equipment requires prior consent except for strictly necessary cases.
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7
Review the cookie policy page for completeness and clarity D+8
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8
Test consent withdrawal and preference change flows D+9
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9
Scan for tracking pixels, fingerprinting, and server-side tracking D+10
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10
Audit embedded third-party content (maps, video, social embeds) D+11
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11
Update the RoPA with cookie-related processing activities D+12
Article 30: analytics and marketing cookies are processing activities and must be recorded with purpose, legal basis, and retention.
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12
Schedule the next cookie audit (recommended quarterly) D+14