Sep 9, 2025
How to Write a GDPR-Compliant Cookie Policy (5-Step Guide)
Introduction
You know you need a cookie policy, but where do you even begin? Staring at a blank page and trying to translate complex legal requirements into a clear, compliant document can be a daunting task. The General Data Protection Regulation (GDPR) has strict rules about how you must inform users about cookies and obtain their consent, and a simple mistake can lead to significant fines.
The good news is that you don't need to be a lawyer to create a compliant cookie policy. By breaking it down into a few essential components, you can create a document that not only satisfies your legal obligations but also builds trust with your website visitors. This 5-step guide will walk you through the process of writing a clear and effective GDPR-compliant cookie policy.
Step 1: Explain What Cookies Are (In Simple Terms)
Start your policy by assuming your reader has never heard of a cookie. Avoid technical jargon. A simple, one-paragraph explanation is all you need.
Example: "Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site. For example, a cookie might remember the items in your shopping cart or your language preference."
Step 2: Disclose Exactly What Cookies You Use
This is the most critical part of your policy. You must be transparent about the specific types of cookies your website uses. Group them into logical categories.
Strictly Necessary Cookies: These are essential for the website to function (e.g., cookies that enable a user to log in or use a shopping cart).
Performance/Analytics Cookies: These collect anonymous data on how visitors use your website (e.g., Google Analytics).
Functionality Cookies: These remember choices you make to improve your experience (e.g., remembering your username or region).
Targeting/Advertising Cookies: These are used to deliver relevant ads to you (e.g., the Facebook Pixel or Google Ads cookies).
For each category, list the specific cookies you use, what purpose they serve, and how long they remain on the user's device.
Step 3: Explain How Users Can Control Their Cookies
Under GDPR, users must have the ability to accept or reject non-essential cookies. Your policy must clearly explain how they can exercise this control.
Describe your cookie banner: Explain that users can set their preferences via the cookie consent banner that appears when they first visit your site.
Provide browser-level instructions: Include a section that explains how users can manage cookies through their web browser settings (e.g., Chrome, Firefox, Safari), and provide links to the browsers' help pages.
Step 4: Detail Your Use of Third-Party Cookies
You must be explicit about any third-party services that place cookies through your site. This includes common tools like Google Analytics, Facebook, Stripe, and any advertising partners. Name these third parties and link to their respective privacy policies so users can get more information.
Step 5: Provide Contact Information and Update Date
End your policy with clear information on how users can contact you with questions about your use of cookies. It’s also a legal and best-practice requirement to include the date the policy was last updated, which shows that you are actively maintaining and reviewing your compliance documents.
Conclusion
A GDPR-compliant cookie policy is a non-negotiable requirement for any modern website. By following these five steps, you can move beyond confusing templates and create a clear, transparent, and legally sound document. Not only will this protect your business from potential fines, but it will also show your customers that you respect their privacy and are committed to handling their data responsibly—a crucial step in building lasting trust.
Frequently Asked Questions (FAQ)
Do I need a cookie policy if I only use Google Analytics?
Yes. Google Analytics sets cookies to track user behavior. Under GDPR, these are considered non-essential analytics cookies, and you must disclose their use and obtain user consent before they are placed.
Is a cookie policy the same as a privacy policy?
No, but they are closely related. A privacy policy is a broad document explaining all of your data processing activities. A cookie policy deals specifically with your use of cookies. Best practice is to have a detailed cookie policy as a separate document and link to it from within your main privacy policy.
How often should I update my cookie policy?
You should review and update your cookie policy at least once a year, or whenever you add new technologies or third-party services to your website that use cookies (e.g., adding a new marketing analytics tool).
What is a "cookie wall"?
A cookie wall is a practice where a website blocks a user from accessing any content until they consent to all cookies. This is generally considered non-compliant under GDPR because consent must be freely given, not forced.
How can I find out what cookies my website is using?
You can use your browser's built-in developer tools to inspect the cookies being set on your site. However, for a comprehensive and automated audit, using a specialized tool like the Klaro Comply Website Scanner is the most reliable method.
Don’t find the answer? We can help.
Find the right validation for your needs
Save up to 35% when you purchase multiple validation packages at checkout.
