Hi @jeannettekoschmann,
Could you please show us where it’s stated in the German rules, that detailed cookie information is need on the first layer of a cookie banner, meaning the actual first impression of the banner.
The example you mentioned, shows the cookies on the second to third layer, including interactions like clicks and scrolling. Which is not much different than our cookie policy.
We opted for legal policies that can act in context of other policies, and can explain certain concepts and define the techniques used, without the need to fit it to a small portion of the screen.
The short answer is we probably will not opt for a Consent Banner that includes details about cookies, as it contributes to a negative, complex user experience providing a lot of texts and jargon in a small font-size, without context.
Let me know if you have any questions,
regards Aert
Thanks a lot for your quick reply! Our data protection officier make this advise to me and showed me the following page (https://lfd.niedersachsen.de/startseite/themen/internet/datenschutzkonforme-einwilligungen-auf-webseiten-anforderungen-an-consent-layer-194906.html), where you can find a pdf document (https://lfd.niedersachsen.de/download/161158) with all necessary information how to set-up a cookie banner in Germany. I’m sorry it’s not translated. I was hoping that customization with some code will help to allow selection of agreement and listing of all cookies in the first layer. Thanks anyway for your time!
This is what he mentioned: the banner could be considered inadmissible by the supervisory authorities, since one agrees to services that one is not notified of at this point in time. Things are different under “Manage Services” because everything is neatly listed there. Have you asked the manufacturer if they have hidden the function somewhere or if they plan to offer it that way? Because everything else is not GDPR-compliant and does not only affect Germany, but all EU countries.
Hi @jeannettekoschmann,
With a first quick scan, I do not see any mention in this PDF that your example would be a better fit, as they both add information about cookies and servcies in subsequent layers, starting with categories on the first consent layer.
If you DPO has another opinion on consent layer, that’s fine. But the article specifically mentions consent layers getting extremely complex due to the variety and information needed to comply. Moving everything in to the first layer, or in our opinion in the same small box, causes another issue of compliance, which is creating a clear, simple and effective way for the user to revoke or consent.
For what it’s worth, visiting “Manage Services” is not only a listing but, in our opinion, a better way to understand what your consenting to.. you can manage consent on this policy as well. Which then acts as our second layer.
regards Aert
Hi Aert! Thanks for your valuable feedback. I would like to stay with Complianz as I’m using it since one year on 4 different web pages 😉
Thanks for quick support!