Lewis Silkin are most popular: <\/p>\n
\n within Cannabis & Hemp, Law Practice Management and Transport topic(s)
\n in United Kingdom
\n with readers working within the Retail & Leisure industries
<\/p>\n
As users increasingly engage with digital services across a wide
\nrange of devices, often while logged into a personal account,
\nonline service providers are increasingly looking for ways to
\nobtain user preferences for the use of cookies and other similar
\n‘storage and access’ technologies via a single consent and
\nto have each user’s choices applied automatically across all
\nauthenticated environments they use.<\/p>\n
Recognising this shift, the Commission nationale de
\nl’informatique et des libert\u00e9s (CNIL), France’s data
\nprotection authority, has published recommendations on how such
\nmulti\u2011device consent mechanisms can be implemented in a way
\nthat is both legally compliant and user friendly. The
\nrecommendations aim to help organisations adapt to users’
\nexpectations of consistency as they switch between phones,
\ncomputers, tablets and connected televisions. This overview
\nsummarises the CNIL’s position and considers how it compares
\nwith the current approach of the UK’s ICO.<\/p>\n
Scope and core expectations<\/p>\n
The recommendations focus on authenticated environments that the
\nCNIL refer to as “logged-in universes”, where consent is
\nlinked to the user’s account rather than to the specific device
\nthey are using. The guidance is relevant not only to websites and
\nmobile applications but also to connected televisions, gaming
\nconsoles, voice assistants and connected vehicles, all of which may
\nrequire consent under Article 82 of the French Data Protection
\nAct.<\/p>\n
Ensuring transparency for users<\/p>\n
The CNIL emphasises the importance of transparency and clear,
\ntimely user information. Details of any multi\u2011device consent
\nmechanism should be provided on the first layer of the consent
\ninterface, ensuring that users understand from the outset how their
\npreferences will be applied. Where a user logs in on a device that
\nhas not previously been linked to their account, organisations
\nshould display a temporary notification indicating that the consent
\nchoices saved to the account now apply to that device, or that
\nthose choices have been updated. This approach helps users remain
\naware of how their preferences operate as they move between
\ndevices.<\/p>\n
The recommendations also address situations where conflicting
\npreferences arise \u2013 for example, where a user expresses a
\nchoice on a device before authenticating that differs from the
\nsettings stored in their account. In such cases, the CNIL accepts
\ntwo possible approaches: either the most recent choice made on the
\ndevice takes precedence, or the preference associated with the
\nauthenticated account prevails. Regardless of the approach adopted,
\norganisations must clearly explain how any conflict is resolved so
\nthat users understand which choice ultimately applies. The CNIL
\nfurther encourages convergence towards a common industry approach
\nto reduce user confusion.<\/p>\n
Finally, the CNIL draws a clear distinction between
\nauthenticated and non-authenticated environments. Preferences
\nexpressed outside of an authenticated session must not be
\noverridden by account level settings. This is particularly
\nimportant for shared devices, such as family computers or connected
\ntelevisions, where applying one individual’s account-based
\npreferences could adversely affect other users. The recommendations
\ntherefore stress that authenticated consent choices should not be
\npropagated to such shared, non-authenticated contexts.<\/p>\n
Data minimisation and moving to multi device
\nmodels<\/p>\n
In line with the GDPR principles of data minimisation and
\nprivacy by design, the CNIL requires organisations to avoid sharing
\nclear text personal identifiers, such as email addresses or
\nusernames, with consent management providers. Instead,
\norganisations should rely on technical or pseudonymous identifiers
\nto link devices securely, reducing the exposure of directly
\nidentifiable data.<\/p>\n
Where an organisation implements a new multi\u2011device
\nconsent model, the recommendations make clear that fresh user
\nconsent is required. Consent previously obtained cannot be relied
\nupon, as users will not have been informed that their choices could
\nbe applied across multiple devices. Earlier consent is therefore
\ninvalid for this form of cross\u2011device processing.<\/p>\n
Although not mandatory, the CNIL also encourages organisations
\nto offer users the ability to manage their preferences on a
\ndevice-by-device basis through a dedicated preferences centre. This
\nreflects the practical reality that individuals may use different
\ndevices for different purposes and may wish to exercise more
\ngranular control over how their personal data is processed.<\/p>\n
Position of the UK ICO<\/p>\n
In contrast to the CNIL, the UK ICO has not issued guidance that
\nspecifically addresses multi\u2011device consent mechanisms or the
\ncross\u2011device synchronisation of cookie and other ‘storage
\nand access’ technology preferences.<\/p>\n
It remains to be seen whether the ICO will develop its guidance
\nin this area, but meanwhile organisations looking to develop a
\nmulti\u2011device consent model may wish to align with the
\nCNIL’s expectations for the purposes of the UK’s Privacy
\nand Electronic Communications Regulations 2003 (PECR). The ICO has
\nconsistently emphasised the need for clear and comprehensive user
\ninformation, consent obtained before any tracking takes place,
\ntransparency around the use of tracking technologies, and the
\nability for users to withdraw consent easily. These principles
\nalign closely with a multi\u2011device approach that is built
\naround informed user choice and effective control.<\/p>\n
Future developments<\/p>\n
Looking ahead, the CNIL has indicated that its work in this area
\nwill continue. In particular, it plans to examine
\n“cross\u2011domain” consent models during 2026, which
\nwould address scenarios where a single consent choice could apply
\nacross multiple websites or services operated within the same
\ncorporate group. If developed carefully, this approach could
\nfurther reduce repetitive consent requests while preserving
\nmeaningful user choice and control.<\/p>\n
The content of this article is intended to provide a general
\nguide to the subject matter. Specialist advice should be sought
\nabout your specific circumstances.<\/p>\n","protected":false},"excerpt":{"rendered":"Lewis Silkin are most popular:
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