CNIL public consultation on multi-terminal consent

Growing use of multi-device consent solutions

Scope

Users now interact with websites or mobile applications from a variety of devices: computers, smartphones,  connected TVs... Sometimes, they do so while being logged into a user account and service providers may seek to obtain one consent for a same users on multiple devices. 

Indeed, when users access a website or mobile application, they may express their choices about the use of cookies or other tracking technologies on a device connected to their account. These choices could then be automatically applied to all devices connected to their account (smartphones, tablets, computers or connected TVs as well as the browser or application used to access a service). 

However, challenges emerge when conflicting decisions can be taken, for instance when a device settings conflict with an account setting. The drafted recommendation provides several options to address these challenges.

The CNIL recommendation

The CNIL wishes to build recommendations on the methods for validly collecting multi-devices consent for cookies. This recommendation will amend  the recommendation on the use of cookies and other trackers published by the CNIL on 17 September 2020.

It's in this context that CNIL opens a public consultation to all actors in order to elaborate its recommandations :

• This consultation will end on 5 June 2025. At the end of this period, the CNIL will examine the contributions and adopt a final version of the recommendation.
• Any public or private stakeholder concerned may take part in the consultation, including academics. In particular, the CNIL wishes to mobilise the digital players targeted by the draft recommendation (publishers, the advertising ecosystem, etc.) as well as citizens and civil society.
• The CNIL invites stakeholders from the same organisation or sector to combine their comments in a single contribution if possible, in particular by contacting their representatives, network heads, federations, associations, etc. 
• The consultation form is in French, but you may participate in English.
• Responses to the public consultation may be subject to FOIA Request. Please indicate in your response if there are elements that are protected by IP law.