We seek to maintain full compliance with the ICO regulations in force from 26th May 2012.

It is widely accepted that the International Chamber of Commerce (ICC’s) clear and concise guidance on cookie regulations, though not constituting legal advice, provides the best guidance in lieu of any official documentation from ICO.

To that end we categorise cookie use as follows:

  • Strictly necessary: to fit this category, the cookie must be related to a service provided on the website that has been explicitly requested by the user. Obvious cases include shopping cart cookies and access to protected areas. We also include cookies which remember previously entered text, so it’s not lost if the page refreshes in this category. This is in line with ICC suggestion.
  • Performance-based: the ICC guidelines includes analytics, advertising and Pay Per Click cookies in this category,  provided they only store anonymous data and cannot therefore be used for behavioural targeting of ads.
  • Functionality based: these include cookies that remember user choices so that they have a more personalised experience. This may include detecting if the user has already seen a popup so that it isn’t shown again, submitting comments and remembering colours, text size etc.
  • Targeting/advertising-based: primarily these are the cookies that the ICO regulations were originally aimed at. This is aimed to cut out creepy and nefarious cookie usage, e.g. the way ads can seem to follow us around the internet – they work by collecting information about our browsing habits which is then used to serve up targeted ads. We agree with the ICC guidance on these cookies, which advises website owners to get clear, explicit consent from users if the site employs such technology.

We will ask for user consent in the event of using category four cookies.

We do not ask user consent for category one, two and three cookies on our websites.

We adhere to the ICC guidance in which no opt-in is required for these types of cookies by the user.

Concerns or questions over our cookie usage? Please contact us.