GDPR Article 7

Conditions for consent

  • Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data.

  • If the data subject's consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding.

  • The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.

  • When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.

· GDPR Article 7 Compliance Guide

Article 7 of the GDPR establishes the requirements for valid consent as a legal basis for processing personal data. While obtaining proper consent may seem challenging, implementing these requirements effectively can build trust with your customers while ensuring compliance.

Core Requirements: Breaking Down Article 7

1. Demonstrable Consent

You must be able to prove consent was given – not just claim it happened.

2. Clear and Distinguishable Requests

Consent requests must stand out from other information and be easily understood.

3. Easy Withdrawal

Withdrawing consent must be as simple as giving it.

4. Freely Given

Consent cannot be bundled with other services or made a condition for service when unnecessary.

Practical Implementation Guide

Building Demonstrable Consent Systems

Documentation Strategy:

  • Create comprehensive consent records containing:

    • What the individual consented to (specific purposes)

    • When consent was obtained (timestamp)

    • How consent was obtained (method)

    • The exact wording presented to the individual

    • Who obtained the consent (if relevant)

Technical Implementation:

  • Use time-stamped database entries for online consent

  • Implement electronic signature solutions for digital forms

  • Design consent workflows that automatically generate audit trails

Creating Clear Consent Requests

Design Best Practices:

  • Use visual separation techniques (boxes, different colors, fonts)

  • Implement multi-layered notices with summaries and detailed explanations

  • Create purpose-specific consent options rather than bundled consent

Language Guidelines:

  • Write at approximately 8th-grade reading level

  • Avoid legal jargon and technical terminology

  • Test consent language with representative users

  • Consider using icons or visuals to enhance understanding

Implementing Easy Withdrawal Mechanisms

User-Friendly Withdrawal Tools:

  • Create a dedicated "Consent Management" section in user accounts

  • Implement one-click unsubscribe links in all communications

  • Establish clear consent withdrawal procedures for phone/in-person requests

  • Design automated systems to process withdrawals within 24 hours

Staff Training:

  • Train customer service teams to recognize and properly handle withdrawal requests

  • Create scripts for handling withdrawal scenarios

  • Document withdrawal procedures in employee handbooks

Ensuring Freely Given Consent

Service Decoupling Strategy:

  • Review all processes where consent is requested

  • Separate necessary processing (contract performance) from optional processing

  • Create clear "No thank you" options with no negative consequences

  • Document your reasoning for data processing that's truly necessary

Conditional Service Assessment:

  • Conduct an audit of all services requiring consent

  • Document justification for any conditional consent requirements

  • Implement alternative options where feasible

Testing Your Consent Framework

Create a regular review cycle that tests:

  • Whether your consent mechanisms are working correctly

  • If withdrawals are being processed promptly

  • Whether staff understand consent requirements

  • If your documentation is complete and accessible

· GDPR Article 7 Compliance Guide

Article 7 of the GDPR establishes the requirements for valid consent as a legal basis for processing personal data. While obtaining proper consent may seem challenging, implementing these requirements effectively can build trust with your customers while ensuring compliance.

Core Requirements: Breaking Down Article 7

1. Demonstrable Consent

You must be able to prove consent was given – not just claim it happened.

2. Clear and Distinguishable Requests

Consent requests must stand out from other information and be easily understood.

3. Easy Withdrawal

Withdrawing consent must be as simple as giving it.

4. Freely Given

Consent cannot be bundled with other services or made a condition for service when unnecessary.

Practical Implementation Guide

Building Demonstrable Consent Systems

Documentation Strategy:

  • Create comprehensive consent records containing:

    • What the individual consented to (specific purposes)

    • When consent was obtained (timestamp)

    • How consent was obtained (method)

    • The exact wording presented to the individual

    • Who obtained the consent (if relevant)

Technical Implementation:

  • Use time-stamped database entries for online consent

  • Implement electronic signature solutions for digital forms

  • Design consent workflows that automatically generate audit trails

Creating Clear Consent Requests

Design Best Practices:

  • Use visual separation techniques (boxes, different colors, fonts)

  • Implement multi-layered notices with summaries and detailed explanations

  • Create purpose-specific consent options rather than bundled consent

Language Guidelines:

  • Write at approximately 8th-grade reading level

  • Avoid legal jargon and technical terminology

  • Test consent language with representative users

  • Consider using icons or visuals to enhance understanding

Implementing Easy Withdrawal Mechanisms

User-Friendly Withdrawal Tools:

  • Create a dedicated "Consent Management" section in user accounts

  • Implement one-click unsubscribe links in all communications

  • Establish clear consent withdrawal procedures for phone/in-person requests

  • Design automated systems to process withdrawals within 24 hours

Staff Training:

  • Train customer service teams to recognize and properly handle withdrawal requests

  • Create scripts for handling withdrawal scenarios

  • Document withdrawal procedures in employee handbooks

Ensuring Freely Given Consent

Service Decoupling Strategy:

  • Review all processes where consent is requested

  • Separate necessary processing (contract performance) from optional processing

  • Create clear "No thank you" options with no negative consequences

  • Document your reasoning for data processing that's truly necessary

Conditional Service Assessment:

  • Conduct an audit of all services requiring consent

  • Document justification for any conditional consent requirements

  • Implement alternative options where feasible

Testing Your Consent Framework

Create a regular review cycle that tests:

  • Whether your consent mechanisms are working correctly

  • If withdrawals are being processed promptly

  • Whether staff understand consent requirements

  • If your documentation is complete and accessible

· GDPR Article 7 Compliance Guide

Article 7 of the GDPR establishes the requirements for valid consent as a legal basis for processing personal data. While obtaining proper consent may seem challenging, implementing these requirements effectively can build trust with your customers while ensuring compliance.

Core Requirements: Breaking Down Article 7

1. Demonstrable Consent

You must be able to prove consent was given – not just claim it happened.

2. Clear and Distinguishable Requests

Consent requests must stand out from other information and be easily understood.

3. Easy Withdrawal

Withdrawing consent must be as simple as giving it.

4. Freely Given

Consent cannot be bundled with other services or made a condition for service when unnecessary.

Practical Implementation Guide

Building Demonstrable Consent Systems

Documentation Strategy:

  • Create comprehensive consent records containing:

    • What the individual consented to (specific purposes)

    • When consent was obtained (timestamp)

    • How consent was obtained (method)

    • The exact wording presented to the individual

    • Who obtained the consent (if relevant)

Technical Implementation:

  • Use time-stamped database entries for online consent

  • Implement electronic signature solutions for digital forms

  • Design consent workflows that automatically generate audit trails

Creating Clear Consent Requests

Design Best Practices:

  • Use visual separation techniques (boxes, different colors, fonts)

  • Implement multi-layered notices with summaries and detailed explanations

  • Create purpose-specific consent options rather than bundled consent

Language Guidelines:

  • Write at approximately 8th-grade reading level

  • Avoid legal jargon and technical terminology

  • Test consent language with representative users

  • Consider using icons or visuals to enhance understanding

Implementing Easy Withdrawal Mechanisms

User-Friendly Withdrawal Tools:

  • Create a dedicated "Consent Management" section in user accounts

  • Implement one-click unsubscribe links in all communications

  • Establish clear consent withdrawal procedures for phone/in-person requests

  • Design automated systems to process withdrawals within 24 hours

Staff Training:

  • Train customer service teams to recognize and properly handle withdrawal requests

  • Create scripts for handling withdrawal scenarios

  • Document withdrawal procedures in employee handbooks

Ensuring Freely Given Consent

Service Decoupling Strategy:

  • Review all processes where consent is requested

  • Separate necessary processing (contract performance) from optional processing

  • Create clear "No thank you" options with no negative consequences

  • Document your reasoning for data processing that's truly necessary

Conditional Service Assessment:

  • Conduct an audit of all services requiring consent

  • Document justification for any conditional consent requirements

  • Implement alternative options where feasible

Testing Your Consent Framework

Create a regular review cycle that tests:

  • Whether your consent mechanisms are working correctly

  • If withdrawals are being processed promptly

  • Whether staff understand consent requirements

  • If your documentation is complete and accessible