Part II of my assessment of the EDPB’s new guidelines on the ePrivacy rule on cookies, mentioning URL tracking, pixels, user identifiers and IP addresses. I announced this would be a negative review – I’m left with the impression that the “guidelines” were drafted with a particular intent in mind.
The words of the ePrivacy Directive seem to have been twisted (both compared to the Recitals and provisions themselves, and from a general linguistic perspective), and technical considerations seem to be weak, only in support of a particular idea of what the rules should cover.
It’s a detailed analysis, so please read to the end before commenting!
(Part I was about whether the EDPB even has the authority to adopt such “guidelines”, as that this is transposing GDPR powers in a way that doesn’t make sense given the EDPB’s composition and given that this does not have the same scope as other data protection rules)
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