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Tag: sats

  • Final storage and access technologies guidance published

    ico.org.uk

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    Concatena says

    Our Take: I’ve not had a chance to fully read into this yet, but my initial big takeaway is the uphill battle that the ICO has in trying to convince people that terms like SATs mean the same thing as they understand when they here cookies. I know how they feel, it’s driven me mad for years, but sometimes you need to meet people where they are. I’m slightly concerned about the references to consulting with the online advertising industry to help shape future initiatives – I’d really like to see consultation with third sector or indeed businesses who are reliant on the advertising revenue but also value their customers to pitch in here too. Final thought is to about how it’s intended that “demonstrably low privacy risks” are quantified. In 2004 I remember the then commissioner, Richard Thomas, warning that we were sleepwalking into a surveillance society. Whilst the current commissioner has stepped away for a while, I hope the ICO still remembers that report.

    Your Takeaway: Nothing really to see here, yet – but if online tracking or advertising is important to your business, or to your ethics, it’s worth a closer read – and maybe getting involved in the ongoing discussions.

    The ICO has today published its finalised guidance on Storage and Access Technologies (SATs), alongside an update on its online tracking strategy.

    Highlights

    The guidance, which covers how the Privacy and Electronic Communications Regulations (PECR) (and where relevant, the UK GDPR) apply to cookies, tracking pixels, device fingerprinting and similar technologies (‘storage and access technologies’), incorporates updates following two consultations and changes introduced by the Data (Use and Access) Act. It includes new examples and points of clarification to help organisations comply with the law. It reflects the law as it currently stands, and sits separately from our ongoing work to review regulation 6 of PECR for online advertising purposes, on which further updates will follow in the coming weeks.

    We have today published our finalised guidance on Storage and Access Technologies (SATs), alongside an update on our online tracking strategy.

  • Online tracking strategy update – April 2026

    ico.org.uk

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    Concatena says

    Our Take: We’ve commented on the SATs guidance in a separate post, but this wider summary from the ICO is worth a read too. I still don’t love the focus on consent for “cookies/SATs” (and don’t even get me started on consent-or-pay) – I don’t see how the average user can possibly understand the network that lies behind that little button – but that’s the legal landscape were in.

    Your Takeaway: As with the SAT guidance, there’s nothing requiring action here yet (unless you didn’t check your cookie banner compliance last year… in which case, I’d recommend a look now). Still, some ongoing discussions here it’s worth keeping on top of – and contributing to as well.

    At the start of 2025, we published our online tracking strategy setting out our plans to give people meaningful choice and control over how they are tracked online, and provide businesses with certainty to innovate responsibly.

    Highlights

    After careful consideration and review of our concerns, we concluded that further action would not be appropriate after observing positive improvements from the platforms as compared to their historical processing practices. This was communicated to the platforms in January of this year.

    We assessed key areas of concern, including: the validity of consent for the data processing carried out by these platforms and their lawful basis relied upon for processing.

    We have driven improvements in the standard products offered to website owners by working directly with key cookie banner vendors responsible for the largest market shares across the UK’s most popular websites. For example, OneTrust and Usercentrics have developed UK-specific templates aligned with our guidance. This is in addition to a range of other improvements made by these platforms and changes implemented by Sourcepoint and Inmobi to enhance their existing templates and guidance. This engagement has raised the bar across a significant portion of the market and made it easier for online businesses to offer fair, compliant choices to users.

    We committed to reviewing cookie banners on the top 1,000 websites in the UK. As we updated in December, our action has seen significant changes. It has lowered the prevalence of cookies being placed before a user has expressed their choice and has driven an increase of clear reject options on consent banners, making it easier for users to control how they are tracked.

    Next month, we will be publishing our advice to government on where PECR requirements to obtain consent for the use of storage and access technologies for online advertising purposes could be removed. We understand that the government is exploring whether to create an exception or exceptions for some online advertising purposes, using secondary regulation-making powers under regulation 6A of PECR. This work will help inform government policy–making.

    Last year, we opened a call for views on our review of regulation 6 PECR where the use of storage and access technologies for advertising may pose demonstrably low privacy risks.