For example, as the GDPR requires that a controller must be able to demonstrate that valid consentwas obtained, all presumed consents of which no references are kept willautomatically be below theconsent standard of the GDPR and will need to be renewed. Likewise as the GDPR requires a“statement or a clear affirmative action”, all presumed consents that were based on a more impliedform of action by the data subject (e.g.a pre-ticked opt-in box) will also not be apt to the GDPRstandard of consent.

The cookie banner will be displayed any time a user visits your site for the first time or when you have decided to add a new vendor to your list of vendors (since it’s a new disclosure and potentially a consent request for that vendor may be required).