Privacy Banner Requirements

I’m writing product requirements for the privacy banner in a new web site. The site carries no advertising and does nothing ugly in terms of privacy. It doesn’t even use Google Analytics. On top of this, the banner is pro forma – users don’t care. This should be a five minute project.

I googled around for how sites are supposed to act on clicks in a privacy banner and didn’t find a standard reference for ultra simple cases like this. The best I found is this well-informed but way overpowered guide. I guess each developer needs to go deep and figure it out themself. That’s silly. So, for the sake of sharing with developers looking for the same thing in the future, here is what I have so far.

The formatting is messy because WordPress isn’t the right tool for this. If you see flaws apart from that, let me know and I’ll incorporate them.

1. There must exist a privacy policy. The privacy policy must inform the user that:

a. The site uses analytics to perform tracking within the site.

b. The site uses cookies for session management.

c. They can delete their account in the profile page, once they are signed in.

d. It is not possible to use pages which require authentication if they do not accept cookies.

2. There must exist a terms of service which new users must accept. The terms of service must state that the site cannot be used without cookies.

3. A user must be able to delete their account. There must be a feature to do this on the profile page. Deletion must remove all trace of the user.

4. All pages which require a user to be authenticated should check to see whether the user has previously opted in or out of cookies, and show a cookie warning if not.

5. The cookie warning should be unobtrusive. It should not impair usability for users who see it but choose to ignore it.

6. The cookie warning should:

a. State that the site uses cookies

b. Link to the privacy policy

c. Offer an option to accept cookies

d. Offer an option to reject cookies

7. If the user rejects the cookie warning, cookies should be cleared and links within the page should have a parameter attached to say that there should be no tracking. On loading any view with that parameter in the URL, these same steps should be followed: cookies should be cleared and links within the page should have the parameter appended. However, these rules will not apply to any page which requires authentication, such as a user dashboard.

8. If the user accepts the cookie warning, the cookie banner should be cleared and a cookie should be set to not ask again.

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