Propose new functionalities for Decidim software
#DecidimRoadmap Designing Decidim together
**Is your feature request related to a problem?**
Decidim's current cookie banner is not compliant with the EU cookie laws. In several countries this could result into fines being made to the website owners.
Here is a little sum up of the things that we need to have in order to be compliant :
- By default, all optional cookies are disabled ( Matomo, Google, etc... )
- Cookies necessary for the platform must be mentioned and justified.
- The user must be able to revoke the acceptance of cookies at any time, in the footer or privacy policy or elsewhere, as desired.
- Block all cookies from external services by default (analytics, embeds etc.)
Currently we do none of these by default on the Decidim install.
**Describe the solution you'd like**
Implement an existing solution that allows us to do all these things. We've started a development on our end (https://github.com/OpenSourcePolitics/decidim/tree/feature/GDPR_compliance_update) but stumbled upon thanks to one of our clients on which provide a simple and acessible solution to this problem : https://github.com/empreinte-digitale/orejime it allows to :
- Set a default configuration with default Decidim cookies
- Update the default configuration according to the needs of the instance (Save in base a script that will be injected in the views...).
- Block the automatic setting of cookies from a third party platform.
We've identify 2 complexity factors :
- One related to the multi-tenant mode of Decidim. Different cookies could be set for each organization
- One related to external services such as embed (youtube), drag and dropped images from imgur and external services which can inject cookies that we would be co-responsible of.
**Describe alternatives you've considered**
Something should be done to make Decidim compliant to the cookie law
**Additional context**
None
**Does this issue could impact on users private data?**
Yes as user have to give their consent for each optional cookie.
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Conversation with Antti Hukkanen
This is important topic, but just to add few things to the discussion:
- There are national differences in the interpretation of the EU law. E.g. in Finland, users can have given consent to store cookies using their browser settings.
- Only thing we have been asked so far is to add a "reject" button in the cookie consent banner which would take the user out of the website to a configured URL stating that they cannot use the service without giving consent.
- Another possible way is to use such obtrusive cookie banners as they use on most of the news sites. This way the user would either give their consent or leave the website before storing any cookies to their browser. This is, however, irritating to most users so you will scare some people away with this approach.
- If you require the consent to be given before adding any tracking scripts to the user, you will lose a lot of analytics data when using the current unobtrusive method.
Here is the full national interpretation for Finland:
https://www.kyberturvallisuuskeskus.fi/en/our-activities/regulation-and-supervision/confidential-communications
"Finland interprets the Directive on privacy in electronic communications (‘ePrivacy Directive’) so that users can give their consent to store cookies on their terminal equipment, for example, by using the appropriate settings of a browser or other application."
It still requires telling the user clearly about the cookies the site sets and the purpose of those cookies being set. The national difference is that for the explicit consent it is enough to assume the user has disabled cookies from their browser if they don't want to allow the sites to store any cookies.
A small update regarding this from Finland:
https://cutt.ly/wyD5OfT
The Deputy Data Protection Ombudsman has hiven order for the first Finnish company to improve their cookie consent implementations according to the EU laws.
It should be still noted that the default functionality in Decidim does not require any additional cookie consent as long as you have a page explaining the use of cookies and you clearly inform users about them. This is already the situation in a default Decidim installation with the current cookie banner with a link to the privacy policy page.
The reason for this is that by default Decidim does not set any other cookies than the session cookie which is counted as necessary. The cookie consents are not required for well explained necessary cookies in any EU country.
The problem comes when you add Google Analytics or other such tracking software to the site. In this situation, you will need to have a clear consent from a user action, e.g. using a popup before the user tracking is started for that user.
This is the case only with 3rd party tracking software, such as Google Analytics. When you are using self-hosted tracking software where the data is not sent to a 3rd party, you will not need any extra consents from the user.
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