Cookies have attracted lots of attention recently. I mean the tracking kind, not the edible kind in Christmas patterns and colors.
What does this mean to you or your business?
Consider not using flash cookies if you are currently doing so or considering so. Many people consider flash cookies deceptive and invasive. In fact, a primer on flash cookies by the Electronic Privacy Information Center shows that the breadth of information gathered by these cookies to probably be beyond the comfort zone of today’s privacy-conscious consumers.
Make sure that you have a full understanding of your cookies practices and that of any third party (such as Google Analytics) who provides apps or tools you use in your interface with users. Your PP should spell out exactly what cookies are used, whether they are persistent, whether you use flash cookies, how you use information gleaned from cookies (e.g. do you utilize information for targeted internal or external marketing), whether you share gathered information with third parties, and how users can block cookies (including providing a mechanism to block flash cookies – a key requirement of the ScanScout consent decree). Finally, if you use third-party services that utilize cookies, consider referencing the third-party service’s cookies policy in your PP.