COOKIE POLICY

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Privacy Preference Center

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

Cookie Law in the UK

Privacy and Electronic Communications Regulations

The EU Cookie Directive was implemented into UK law under the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 which are themselves an amendment to the Privacy and Electronic Communications (EC Directive) Regulations 2003.

These regulations came into UK law on 26 May 2011, one day after the deadline set by the EU.

Wording of the UK Regulations

There is one key section of the UK regulations that is relevant to website owners in respect of user consent:

Confidentiality of communications

6.—(1) Subject to paragraph (4), a person shall not store or gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.

(2) The requirements are that the subscriber or user of that terminal equipment— (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent.

(3) Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.

(3A) For the purposes of paragraph (2), consent may be signified by a subscriber who amends or sets controls on the internet browser which the subscriber uses or by using another application or programme to signify consent.

(4) Paragraph (1) shall not apply to the technical storage of, or access to, information— (a) for the sole purpose of carrying out the transmission of a communication over an electronic communications network; or (b) where such storage or access is strictly necessary for the provision of an information society service requested by the subscriber or user.

An everyday interpretation of this would read:

You cannot store or gain access to information stored on a computer, unless the user has been given clear and comprehensive information about what you want to do, and why, and has given their consent to do so.

The exception to this rule is when the user requests a service and that service cannot be provided without storing or gaining access to information stored on their computer.

UK Enforcement of the Regulations

Enforcement of the regulations is the responsibility of the Information Commissioners Office (ICO). They have investigatory powers and the ability to impose fines of up to £500,000 for serious breaches of the regulations.

The ICO’s approach to enforcement is a very light touch one. They have put in place a complaints mechanism, but do not take any proactive investigative action.

As of Spring 2013, the most action they have taken is to make a visual check of sites to see whether or not they have any user notification of the use of cookies. They have the power to force site owners to change their site to comply with the law, but have also said that it is unlikely they would go so far as to impose a fine for non-compliance with the law.

This has led to a situation where many websites either ignore it completely, or try to do as little as possible to avoid the threat of action. Some people have argued that this has led to a situation where online privacy has been diminished as a result of the law, rather than strengthened.