When consent is the right basis.
WHAT VALID CONSENT REQUIRES
Freely given Specific to a purpose Informed Unambiguous, through clear affirmative action
WHAT IS NOT CONSENT
Pre-ticked boxes Silence or inactivity Continuing to use a service Bundled acceptance of terms
WHY BUNDLING FAILS
It is not specific, and refusing is not realistic.
WHAT FREELY GIVEN MEANS
There is a genuine choice, and refusing costs nothing essential.
WHY THAT MATTERS IN EMPLOYMENT
An employee's consent is rarely free, because of the power imbalance.
WHAT TO DO INSTEAD THERE
Rely on another basis.
WHAT TO RECORD
Who consented When What they were told How they indicated it
WHY RECORD IT
You must be able to demonstrate it.
WHAT WITHDRAWAL REQUIRES
Being as easy as giving it.
WHAT THAT MEANS PRACTICALLY
If consent was one click, withdrawal cannot require a phone call.
WHAT TO DO ON WITHDRAWAL
Stop that processing, promptly.
WHAT IT DOES NOT UNDO
Processing already carried out lawfully.
WHAT TO SEPARATE
Consent for different purposes.
WHY
One tick cannot cover marketing, profiling and sharing.
