LNB News 23/01/2025
Document Information
Issue Date: 23 January 2025
Published Date: 23 January 2025
Jurisdiction(s): England, Northern Ireland, Scotland and Wales
The Information Commissioner's Office (ICO) has published comprehensive guidance on 'consent or pay' business models for online tracking. The guidance addresses compliance with data protection law, focusing on key areas such as power imbalance, appropriate fees, equivalence, and privacy by design. ICO has outlined methods for assessing power imbalance, including market position and barriers to switching, as well as determining appropriate fees and ensuring equivalence between options. The guidance also emphasizes the importance of privacy by design principles in implementing these models and cautions against offering them to children.
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