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Cookie Audit and Classification Toolkit

Classify Every Cookie, and Record Why , Not Just What

Four categories, a lawful basis per individual cookie, mapped to what regulators expect.

You have the cookie list. You still can't defend it.

You know which analytics cookies sit on your site, but you are never sure which ones genuinely need consent and which can rest on legitimate interest. Category-level labelling is not enough: a first-party analytics cookie with ad features disabled sits in a materially different position than one that shares data with an ad network. Most teams configure a consent banner before knowing exactly what their site actually sets, which opens a gap between the published policy and real site behaviour. That gap is precisely what regulators scan for.

Cookie Audit and Classification Toolkit

Get instant access to the toolkit

A step-by-step toolkit for building a defensible cookie inventory, classifying every cookie to a lawful basis, and keeping an audit-ready consent record.
  • Written around real GDPR, ePrivacy & CCPA requirements
  • 26-page toolkit across 8 sections
  • Includes the 15-field register schema and lawful-basis mapping table
Cookie Audit and Classification Toolkit

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Written around real GDPR, ePrivacy & CCPA requirements

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The figures that set the benchmarks

Four
Standard categories every cookie must map to: strictly necessary, functional, analytics, advertising.
13 months
CNIL benchmark maximum for trackers and analytics cookies; longer periods are treated as disproportionate.
15 fields
Minimum per-cookie register schema aligned to GDPR Article 30 and CMP consent groups.
Jan 2022
CNIL fined Google and Meta over cookie refusal being harder than acceptance, undermining valid consent.

Why lawful basis is decided cookie by cookie

Under GDPR Article 5(1)(b), each category must map to a specified, explicit purpose before it appears in your banner or policy. Analytics cookies that involve any third-party sharing or profiling require consent under Article 6(1)(a), not legitimate interest, and advertising identifiers require consent in every EU and UK context. The toolkit walks the lawful-basis analysis for each type and shows why first-party versus third-party is a risk multiplier, not a category of its own. It ends with recording the decision and its rationale for each individual cookie, the level of granularity regulators expect to see.

What's inside the toolkit

The four standard categories and the purpose each must map to
The narrow strictly-necessary test, with clear pass/fail examples
Key questions for analytics cookies: third-party sharing, ad-identifier linkage, vendor datasets
The category-to-lawful-basis mapping table (Art. 6) with consent-required flags
First-party vs third-party treated as a risk multiplier, not a category
How to record the lawful-basis decision and rationale per cookie

What you can do once you've read it

Settle the analytics consent question

Decide confidently which analytics cookies need consent and which can sit on a narrow legitimate interest, using three test questions.

Recognise what your scan returns

Named real cookies and vendors (_ga, _fbp, IDE, TDID, _gcl_au) let you match scan output to a category on sight.

Build a register that holds up

A 15-field schema mapped to GDPR Article 30 and your CMP consent groups turns raw scan data into defensible evidence.

Catch disproportionate persistence

Apply benchmark expiry durations and a flagging rule to find cookies whose lifetime exceeds their purpose.

Configure the scan properly

Run an unauthenticated baseline, authenticated roles, scripted journeys, and per-subdomain crawls so nothing is missed.

Cover US state law too

Handle CCPA/CPRA sale and sharing rules and verify GPC signal propagation before any advertising identifier fires.

Grounded in the actual regulatory record

Every claim traces to a named article, ruling, or guideline, not vague best practice.

Cites GDPR Articles 5, 6, 7, 13/14, 28, 30, 46 and Recital 32
References ePrivacy Directive Article 5(3) on prior informed consent
Names the CNIL's January 2022 fines against Google and Meta
Cites CJEU Planet49 (C-673/17) and Meta Platforms v Bundeskartellamt (C-252/21)
References EDPB Guidelines 05/2020 and 1/2024, the ICC UK Cookie Guide, and IAB TCF v2.3
Covers the CNIL 13-month tracker benchmark and Schrems II transfer obligations

Before you download

It depends on the cookie. The toolkit gives three test questions: is the data shared with any third party, is the profile linked to an advertising identifier, and does the vendor build its own datasets. Any third-party sharing or profiling requires consent under Article 6(1)(a); only strictly anonymous aggregate measurement for the publisher's sole benefit may qualify for a narrow basis.

Cookie Audit and Classification Toolkit

Stop guessing categories. Classify every cookie to a lawful basis.

Written around real GDPR, ePrivacy & CCPA requirements.