Internet users and web professionals are invited to give their opinion on the CNIL’s draft recommendation, which aims to support operators in processing the consent of Internet users. After having published its guidelines on the application of article 82 of the law of January 6, 1978, relating to data processing, files and freedoms, the CNIL has just Belize WhatsApp Number List a public consultation on its draft recommendation ” cookies and other tracers ”. According to the CNIL, these guidelines, published on July 4, 2019, aimed to ” summarize the applicable law “. The Commission also specifies: “in order to support the professionals concerned in the implementation of compliant solutions for collecting consent, the CNIL wished to supplement these with practical recommendations which reflect a concrete application of the regulations ” .

Context reminder With the application of the GDPR, the legal framework has greatly evolved in terms of the validity of consent. The stake in the protection of personal data is very high for Internet users. On the other hand, web professionals and, in particular, the online advertising sector, have asked for more clarity as to the CNIL’s recommendations on this subject. The objective of this public consultation: to propose a draft recommendation, intended for public and private organizations, which reflects the opinions of users and web professionals. This project should subsequently lead to a set of operational modalities on collecting the consent of Internet users for operators, who use cookies and other types of tracers on their site. In particular, the debate around the explicit consent of the Internet user in the case of advertising targeting.

Context reminder

We remember in particular the ambivalent position of the CNIL on the scroll as a mode of expression of consent. According to the institution, “the simple pursuit of navigation on a site can no longer be regarded as a valid expression of consent to the deposit of cookies” (an obvious opinion, on reading the RGPD) – but at the same time, the CNIL has announced that the actors would benefit from an “adaptation period, ending six months after the publication of the future recommendation” – more or less until the end of the year therefore, that is to say 2 years and a half after the entry into force of the GDPR. The themes of the CNIL’s public consultation To complete the outlines of its final recommendation, the CNIL is proposing a series of 10 themes, subject to comments and votes by Internet users.


The requirement for informed consent The requirement of free consent On the recommendation in general On the collection of consent via browsers On the scope of the recommendation The requirement for specific consent The requirement of unequivocal consent Withdrawal and duration of consent On proof of consent On the terms of use of cookies For each of these 10 themes, the CNIL proposes to submit a contribution to the different parts of its recommendation. Comments, points of view and other lines of thought raised by Internet users are put to the vote. The CNIL calendar This public consultation is available on the CNIL website for a period of 6 weeks, until February 25. A new version of the draft recommendation, which will integrate the elements of this consultation, will then be presented to the members of the CNIL in plenary session for final adoption.

The themes of the CNIL’s public consultation

This recommendation, once completed, will not be binding. It simply aims to ” formulate practical recommendations on how to operationally translate the requirements of the texts into the presentation of user interfaces “. The CNIL specifies that the text will present concrete examples of the implementation of the regulations in force. around a table, and to make them collectively think about the attractions of the content for their role. respective. Once this “awareness” has been carried out, it is necessary to continue with other more operational workshops, which will consist in laying down a real Content Marketing strategy. If every manager is involved, it is a guarantee that the strategy will cover all the client’s needs, whatever their position in the acquisition and loyalty funnel. Marketing can then take over and ensure the “operational production” of the strategy.

Obviously, it may be interesting to rely on an external resource to lead these workshops. It is indeed necessary to have the necessary experience for such an animation, but also to guarantee a certain balance between the different functions represented. Everyone should feel involved and not think that the content marketing strategy falls to the function of his neighbor. Concretely, how to set up an action plan? Once the strategy has been laid down and documented, it should logically be implemented. At this stage, it is therefore very operational elements that must be activated: Role of the editorial committee : composition, responsibilities of each, frequency of meetings, objectives. Production of the contents themselves : with whom? How? ‘Or’ What ? which validation circuit? should we use subcontracting? if so, for what purpose?


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