Cookie policy
Cookie policy is a policy that explains how a website uses cookies and other tracking technologies.
Explained – what is a cookie policy?
A cookie policy is a document that informs users which cookies are collected, how they are used and how the user can manage them. The policy is closely linked to GDPR and the ePrivacy Directive, which together govern how personal data may be processed and how consent must be obtained. Many organisations engage a GDPR consultant to ensure their cookie policy is clear, accurate and compliant with legal requirements.
When does the cookie policy question arise?
The question of a cookie policy arises whenever an organisation operates a website or digital service that uses cookies or similar tracking technologies. This is particularly relevant when using analytics tools, marketing cookies or third party cookies that process personal data. A policy is needed both to meet legal obligations and to provide transparency to users.
A common example is the use of tools such as Google Analytics and Google Ads, where analytics cookies are used to collect statistics and enable targeted advertising. Because these are not strictly necessary cookies for the basic operation of the website, valid consent is required before they can be set via any cookie consent banner.
Key considerations for your cookie policy
To draft a compliant cookie policy, organisations should take account of several core points that also support cookie banner compliance and best practices.
- Clarify which cookie categories are used, for example strictly necessary cookies, functional cookies, analytics cookies and marketing cookies.
- State the purposes of the cookies, how cookies are used and whether information is shared with third parties.
- Explain how users can manage cookie settings, including how to withdraw or change consent (cookie preferences and consent management).
- Ensure the policy is written in clear, accessible language that users can understand.
- Update the policy regularly to reflect current technical solutions and legal requirements for website tracking and online tracking technologies.
- Link the policy to a clear cookie consent banner that respects the user’s choices and meets cookie banner requirements.
By following these points, organisations can both satisfy legal requirements and build brand trust with their users.
Cookie policy
Why is a cookie policy important?
A cookie policy is important because it provides transparency about how data is collected and used online. It is a key tool for complying with GDPR and the ePrivacy Directive, where consent and the information obligation are central.
Across Europe, the supervisory authority for electronic communications (such as the national telecoms regulator) oversees the ePrivacy rules. Where the use of cookies involves the processing of personal data, the Data Protection Agency also has a central role, as those matters fall under GDPR. Together, the authorities ensure the framework is applied correctly and that individuals’ rights are protected.
A clear cookie policy helps users understand their rights and make informed choices. It strengthens the relationship between companies and users by demonstrating respect for privacy and user control over their data.
In the longer term, a well-drafted cookie policy supports brand legitimacy and trust. When users feel their privacy is handled seriously, the chances of long-term customer relationships and a stronger brand position increase.
Frequently asked questions on cookie policy
It means the authority responsible for electronic communications monitors how the rules on cookies and similar technologies are followed. It ensures organisations meet the requirements for consent and information under the directive and can intervene where shortcomings are found.
A website must have a cookie policy as soon as it uses non-essential cookies, for example for analytics or marketing. This applies regardless of the size of the organisation.
To comply with the law, the policy must be clear, easily accessible and contain all relevant information about cookies. A good policy should include, for example:
- A description of the cookies used (including Google Analytics cookies and Google Ads cookies where relevant)
- Clear purposes for each category and whether data is shared with third parties
- How users can manage cookie settings and withdraw consent via the cookie consent banner
The controller is responsible for ensuring the cookie policy is up to date and meets legal requirements, even if external providers manage technical solutions or cookies.
The ePrivacy Directive complements GDPR by specifically regulating electronic communications and the use of cookies. It establishes, among other things, that consent is required for non-essential cookies and is therefore central when drafting a cookie policy.
The difference lies in the content. A cookie policy explains how cookies and similar tracking technologies are used, while a privacy policy covers the broader processing of personal data. Organisations often need both documents:
- Cookie policy: focus on cookies, purposes and consent (a practical cookie policy template may help)
- Privacy policy: focus on all processing of personal data
- Together they provide a complete picture of data handling (cookie policy vs privacy policy)
Read more about our services
GDPR Lawyer
Engage Morling Consulting’s privacy counsel when personal data issues need to be addressed in a business-focused manner with clear control of risk. We provide support with governance, contracts, transparency and processor arrangements, ensuring the organisation remains consistent towards data subjects and the Data Protection Authority (IMY).
DPIA
We prepare Data Protection Impact Assessments (DPIAs) for processing activities that may pose a high risk and require a documented basis for decision-making. We carry out the assessment, identify risks, and put in place mitigations and documentation so the DPIA is auditable, traceable, and ready for review.
Breach management
Morling Consulting supports incident management when a personal data breach must be handled swiftly and correctly. We lead the assessment, remediation plan and documentation, including materials for notification and communications, so the organisation acts in a coordinated way and reduces consequential harm.
Contact
Contact us
If you prefer phone, please feel free to contact Felix Morling at +46 70 444 42 85
"*" indicates required fields