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New Privacy Consent Banner Mandate for Dealers Aims to Safeguard Customer Data.


  • Data collection & sharing must be Transparent, Consensual, Limited.
  • Data storage & sharing must be Limited, Accurate, Protected.
  • Operate transparently, Be Accountable, Apply these requirements to a website.
A recent ComplyNet study revealed

15% of dealer websites have a consent banner, however, 100% of them were passing data in front of consent.

Likely deceptive and likely a UDAAP violation under state and/or federal law

Privacy Consent Banner

Dealers Need to Have a Cookie Banner on their Website.

To Avoid Fines. Violations of similar laws in Europe have resulted in hefty fines. Example:  France recently fined Google $169M and Facebook $67M for requiring too many clicks for users to opt out of cookies

  • Preference Management
  • Adherence to Industry Standards
  • Mitigation of Risks
  • User Experience Optimization

10-Steps for Navigating Website Privacy Consent Banners

Complynet 10steps NextGen Privacy Laws Final


Step 1

Identify Cookies Collected

Scan your website periodically to identify:

  • Plug-Ins
  • Third Party Collecting Cookies


Step 2

Categorize Cookies

  • Essential Cookies
  • Performance and Functionality Cookies
  • Analytics and Customization Cookies
  • Advertising Cookies
  • Social Networking Cookies
  • Unclassified Cookies


Step 3

Auto-Block Collection

  • Auto-block all cookies until after consent is provided.

Step 4

Privacy/Cookie Policy

  • Create a website privacy policy and cookie policy that identifies the cookies by category and the 3rd party providers collecting cookies.
  • Modify the privacy policy/cookie policy as the website and providers change.

Step 5

Website Banner

  • Create a custom banner that permits the acceptance and rejection of non-essential cookies.


Step 6

Preference Center

  • Allow consumers to change their consent options at any time with a Preference Center


Step 7

Privacy Requests

  • Enable consumers the ability to make privacy requests so that your designated individual may properly respond and manage requests.

Step 8

Review Website

Banner properly installed. No interference with accessibility tool.

Easy access to:

  • Privacy Policy/Cookie Policy;
  • Preference Center; and
  • Privacy Requests.

Step 9

Data Processing Agreements (DPAS)

DPAs typically address issues such as:

  • The specific purposes for which the personal data will be processed;
  • The categories of personal data that will be processed;
  • The duration of processing;
  • The geographic scope of processing;
  • The security measures that will be implemented to protect personal data;
  • The rights of individuals with respect to their personal data; and
  • The obligation of the parties to comply with applicable law.

Step 10

Protect Data (FTC Safeguards Rule)

  • Protect customer information/data collected by adhering to the FTC Safeguard Rule, which you are already required to follow.
  • Revised Rule took full effect on June 9, 2023 with violations of up to $50,120 per violation.


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