Guidelines for cookie banners from NOYB and implementation with CCM19

The well-known lawyer for data protection law Max Schrems founded the organization NOYB (None of Your Business) to take action against companies that use illegal cookie banners on their websites. As part of a project, the NOYB team has since regularly analyzed cookie banners on websites with regard to user-friendliness, transparency and accuracy of content.

To avoid risking a warning, it is therefore important that the cookie banner used on your own website complies with NOYB's strict guidelines. CCM19 has all the features you need for correct configuration and we will show you below how to set up your cookie banner to be NOYB-compliant with just a few clicks.

1. Rejection option directly in the first view

NOYB criticizes that 81% of the cookie banners analyzed do not offer the option to reject all cookies in the first window with just one click. This can easily be ensured by integrating a reject button directly in the first window of the cookie banner:

In CCM19, you can easily set which buttons are displayed in the settings of your active theme:

By default, the buttons for cookie settings and accepting cookies are set. For the third button, simply select the "Reject" entry from the select box to also show the button. You can change the order and color of the buttons as you wish.

2. Categories must not be preselected

In 15% of cases, NOYB found that a preselection had already been made for website visitors in the banner and cookies or cookie categories had already been checked without the user having performed any action.
This pre-selection option is not available in CCM19 due to legal issues; accordingly, there can be no problems here.

3. Use buttons instead of inconspicuous text links

According to NOYB's analyses, around 51% of the websites analyzed try to increase the approval rate by hiding the decline function as an inconspicuous text link in the intro text of the banner.

In CCM19, all interaction options relevant to consent are displayed as buttons by default:

Accordingly, this point on the NOYB checklist is also fulfilled by default with CCM19.

4. Sufficient contrast for buttons

According to research by NOYB, in 73% of cases, weak contrasts are used to make it more difficult to reject cookies. On the one hand, this is possible because the button and font color do not contrast sufficiently with each other. The font is then difficult to read and the button is clicked less often.
In other cases, a rather inconspicuous color is deliberately chosen for the reject button, while the accept button is highlighted in a more prominent color.

In CCM19, you can easily configure the button colors and it is even pointed out if the contrast between the button and font color is too low:

The button color for the reject button can be set separately, so that you can also display the button in a contrasting color with just a few clicks:

This means that this NOYB guideline can also be easily fulfilled with CCM19.

5. Rejecting cookies must be just as easy as accepting them

According to the NOYB, 90% of all cookie banners make it unnecessarily difficult to reject cookies, mainly because more clicks are required to reject cookies than to accept them. Some websites create veritable labyrinths of clicks that have to be passed through in order not to accept all cookies. This deliberately tests the patience of website visitors in order to make consent more likely. This form of influence is rightly strongly criticized by the NOYB project.
CCM19 makes it easy to ensure that visitors to your website can also reject cookies with a single click. All you have to do, as already described under point 1, is to display the Reject button. Like the Accept button, this only requires one click, so rejecting cookies could not be easier.

6. Cookies in the "Technically necessary" category must really be essential for the website function

According to the NOYB, around a quarter of all websites analyzed provide untrue information about the technical necessity of cookies. References to third-party cookies are often missing completely. Since cookies may only be set without consent if they are absolutely necessary for the operation of the website, the definition is sometimes interpreted very broadly and integrations or cookies are declared to be technically necessary, although strictly speaking they are not.

In case of doubt, it is better to choose a category other than "technically necessary" for cookies or integrations. With CCM19, you can easily define the category for each integration and thus ensure that only technically necessary elements are declared as such:

If you make truthful classifications here for every tool used, this NOYB guideline is therefore also fulfilled.

Conclusion

The NOYB guidelines for cookie banners are easy to comply with by carefully configuring CCM19. Many things are already covered by the standard settings and some rule violations, such as the use of text links instead of buttons, cannot be implemented in CCM19 without major effort.

If you have any questions about the NOYB guidelines or implementation with CCM19, please feel free to contact us by email or phone. We will be happy to advise you!