SUMMARY “SOUND BITES” OF 5TH COOKIE BENEFITS: CROSS-REFERENCED TO ICO RTB REPORT CONCERNS

- This analysis is provided by Anonos and may not reflect the opinions of other 5th Cookie working group members -

GENERAL
ACCOUNTABILITY
CONSENT
  • Consent-based data collection and processing does not work in all circumstances - e.g., where processing cannot be described with sufficient detail at the time of data collection. For example, privacy notices may lack clarity, processing may be difficult to define, etc. The GDPR provides for an alternative legal basis for processing - which picks up where consent leaves off - to enable lawful processing in these situations. Data controllers can pick up where consent does not work if the are able to satisfy the requirements for “Legitimate Interest” processing. 5th Cookie helps to support the processing of personal data on Legitimate Interest processing grounds.
  • The 5th Cookie approach begins with consent as the "centerpiece" of the puzzle, but recognises that other "pieces" may be required in certain situations to allow for lawful data processing.
  • When consent-based processing is not appropriate, 5th Cookie principles create a bridge by leveraging Pseudonymisation-enabled Legitimate Interest processing.
TRANSPARENCY
  • Personal data must be “processed lawfully, fairly and in a transparent manner” under the GDPR, and 5th Cookie helps to support transparency with auditable technical records that reflect "demonstrable accountability."
  • With 5th Cookie, technical controls can be embedded in the process and can be demonstrated to auditors, enforcement agencies, and oversight organisations.
LEGITIMATE INTEREST
SCALE & CREATION & SHARING OF DATA
DATA MINIMIZATION/PURPOSE LIMITATION
ADVERTISING FRAUD
MARKET DOMINANCE
VULNERABILITY OF SMALLER PUBLISHERS
  • 5th Cookie supports an open-market system available to everyone, which can help smaller publishers to remain competitive.
PROFILING & AUTO DECISION MAKING
TRACKING OF DATA SUBJECTS
COMBINING AND MATCHING OF DATA
USE OF INNOVATIVE TECHNOLOGY