Users re-prompted when cookie purposes or third parties change
Why it matters
GDPR Art. 7(3) states that a data subject has the right to withdraw consent at any time, and Recital 32 clarifies that consent must be granular and specific to each purpose. When new tracking purposes or third parties are added without re-prompting users, the original consent — even if validly obtained — no longer covers the new processing. ePrivacy Art. 5(3) ties the scope of consent to the specific purposes declared at the time of collection. A user who consented to analytics-only in 2024 has not consented to the marketing pixel added in 2025, and treating their stored preference as blanket consent for all future additions is unlawful.
Severity rationale
Medium because the failure only affects users with previously stored consent — it does not affect new visitors — but it invalidates consent for all returning users when new tracking is added without triggering re-consent.
Remediation
Store a consent version alongside the user's decision and compare it to a CONSENT_VERSION constant on every page load. Bump the constant whenever you add a new third-party service or cookie category.
// src/lib/consent.ts
const CONSENT_VERSION = '1.1' // was '1.0' — bumped when Segment was added
export function needsConsent(): boolean {
const raw = localStorage.getItem('cookie_consent')
if (!raw) return true
const stored = JSON.parse(raw)
return !stored.version || stored.version !== CONSENT_VERSION
}
Add bumping CONSENT_VERSION to your team's checklist for adding any new analytics tool, ad pixel, or embedded third-party service. The banner will automatically re-appear for returning users whose stored version predates the change.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the Cookie & Consent Compliance Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- gdpr · Art. 7(3) — GDPR — withdrawal of consent must be as easy as giving it; re-consent required on purpose change
- gdpr · Recital 32 — GDPR — consent should cover all processing purposes; new purposes require fresh consent
- eprivacy · Art. 5(3) — ePrivacy Directive — consent tied to the stated purposes at time of collection
Taxons
History
- 2026-04-18·v1.0.0·Initial import from cookie-consent-compliance·automated