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It is illegal, at least from the point of view of the GDPR which is what these pop ups are supposed to comply with.

You could argue that the artificial delay is implemented as a way to dissuade people from declining which would fail the idea that data processing consent should be freely given (you can’t force people to opt-in).

You could also argue that even if there was a legitimate technical reason for the delay then it wouldn't be compliant because it would prove that data processing is enabled by default before the user opts-in (otherwise the delay should be on opt-in and opt-out should be instant as it's essentially a no-op).

Here are the ICO’s guidelines on the subject - you’ll see that this TrustArc trash fails on multiple points: https://ico.org.uk/for-organisations/guide-to-data-protectio...

TrustArc essentially provides "breaching the GDPR as a service" and their continued existence proves the incompetence of the data/privacy regulators in all EU countries.



> proves the incompetence of the data/privacy regulators in all EU countries

Or maybe it shows that they are underfunded relative to the task set them. Which is actually true of many government departments.


Conveniently they're allowed to fine offenders up to 4% of global turnover and it's not like there's a shortage of offenders.

Surely there is a way to get this "machine" started and use the money from previous fines to fund future enforcement?


I'm speculating, but I highly doubt that fine money goes back to regulation efforts in full.


It may also be a sign of how much national governments care about privacy, compared to the EU parliament which voted for the e-Privacy Directive.

I suppose the counter-argument would be that passing legislation is cheap, but enforcing it costs money, and governments have other priorities, but, for example, in the UK there can be fines of up to £500,000 for breaches of the e-Privacy Directive[0], which should be more than enough to cover the cost of the investigation.

[0] https://www.pinsentmasons.com/out-law/news/gdpr-e-privacy-br...


Thanks, I figured this was the case.




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