Following its consultation in March 2024, the Information Commissioner's Office (ICO) has published its long-awaited guidance on consent or pay business models. The guidance clarifies under what circumstances organisations can legally deploy consent or pay models to give users meaningful control while supporting their economic viability. The guidance also includes a set of criteria for organisations to assess their models against in order to demonstrate consent is freely given.
In addition, the ICO confirmed that it will expand its cookie compliance campaign to focus on the top 1,000 UK websites.
In a blog article, Executive Director of Regulatory Risk at the ICO, Stephen Almond, discusses the two developments, which form part of the regulator's new online tracking strategy.

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