New GDPR guidelines: Upgrade your solution

2020-09-18 11:10:31 UTC

As of October 1st, 2019, a judgement in Germany ruled that user consent is not valid if it is obtained through a prechecked checkbox or non-explicit accept (for instance by assuming user accept just by using a website). The judgement has caused law enforcement responsible in several EU countries to change their guidelines regarding cookies and similar technologies. Basically, the user must now actively opt in instead of having to opt out to avoid being tracked.

Link to full judgement 

Summary of ruling: “…consent…is not validly constituted if, in the form of cookies, the storage of information or access to information already stored in a website user’s terminal equipment is permitted by way of a pre-checked checkbox which the user must deselect to refuse his or her consent.”

Your ePaper uses statistic cookies and maybe personalized cookies

In your ePaper from Visiolink, usage data is by default collected and sent to Google Analytics/Firebase Analytics. This kind of general tracking cookies are called statistic cookies. In addition, some customers have implemented User Tracking to track the use of content of the individual user. This kind of user tracking cookies are called personalized cookies. Both types of cookies go under the same regulation.

What must change in the ePaper

Visiolink recommends a solution with these prerequisites:

  • All tracking must be inactive, until the user actively gives his/her consent
  • The user must have access to all information regarding the use of data before giving consent (trough a link to your privacy policy)
  • The user must be able to withdraw his/her consent easily at any time

The solution

We are developing a solution that lives up to the prerequisites above. It consists of two steps as seen in illustration below (both the English and the German version are shown, design is not finalized):


Two-step pop-up in both apps and web-solution (English version)


Two-step pop-up in both apps and web-solution (German version)

Step 1: An information pop-up that describes the use of data with the opportunity to give consent by pressing the green “Accept” button. In step 1 it is possible to open your general privacy policy. Pressing “Accept” will close the pop-up and activate tracking. Pressing “Decline” will open the menu in step 2.

Step 2: A menu - that is accessible from within the app at all time – will indicate that tracking is turned off. If the user presses “Save”, the setting is saved on the device.  

How can we upgrade our solution?

By the beginning of March, Visiolink will have this solution ready on iOS, Android and Web. For iOS and Android an upgrade of the app is necessary. Please contact us, if you want to upgrade your apps.

The Web solution will gradually be rolled out across all web solutions during Q1 2020. This will happen automatically. 

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