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Review Consent Management Platform
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A consent management platform (CMP) enables a website or app to inform visitors about the types of data that will be collected, and asks users for consent for specific processing purposes.
A CMP has two critical components:
Front End
Where your users and customers can select what data collection and usage they wish to consent to.
Back End
Where developers map data consent based on versions and locations and track acceptance rates.
The more complex your consent requirements, the more complex your back end and data management processes will be.
If you are collecting and processing data from your users, answer the following questions about your consent management practices.
Do you track consent?
If yes, do you record these consent updates in a verifiable log (i.e., linked to the user record with a timestamp)?
If you answered no to either question, remember: if you don't have a verifiable log, you don't have consent. Build and maintain a verifiable consent management log to remain compliant.
If you track consent, is consent for each feature collected separately, i.e., with a different toggle or opt-in?
If not, remember that according to GDPR consent must be freely given, specific, informed, and unambiguous. In order to obtain freely given consent, it must be given on a voluntary basis.
Is your consent management platform complex i.e., contains many features, locales, and/or disclosure versions?
If yes, do you have a paradigm that establishes relationships so that disclosures and consents can be stored meaningfully in a database?
If your consent management platform is complex, do you maintain all records collected for each user?
If yes, what is the impact of storing that quantity of data, particularly obsolete data?
Do you feel confident in your organization's ability to invoke the database for the latest version of consent provided by a specific user?
If yes, what is the impact of storing that quantity of data, particularly obsolete data?
Next Steps
Reflect on your answers. What are you doing well, and what do you need to improve? Engage your cross-functional team of stakeholders to make a plan.