Deceptive Patterns
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Cookie Banners, What’s the Purpose?: Analyzing Cookie Banner Text Through a Legal Lens

Author
C. Santos, A. Rossi, Lorena Sánchez Chamorro, Kerstin Bongard-Blanchy, Ruba Abu-Salma
Date
6 Oct 2021
Publisher
WPES@CCS
Focus
Law & Policy
Category
Academic Scholar

This paper manually annotated around 400 cookie banners presented on the most popular English-speaking websites visited by users residing in the EU and found that 89% of cookie banners violated applicable laws.

A cookie banner pops up when a user visits a website for the first time, requesting consent to the use of cookies and other trackers for a variety of purposes. Unlike prior work that has focused on evaluating the user interface (UI) design of cookie banners, this paper presents an in-depth analysis of what cookie banners say to users to get their consent. We took an interdisciplinary approach to determiningwhat cookie banners should say. Following the legal requirements of the ePrivacy Directive (ePD) and the General Data Protection Regulation (GDPR), we manually annotated around 400 cookie banners presented on the most popular English-speaking websites visited by users residing in the EU.