Cookie policy distinguishes between first-party and third-party cookies
Why it matters
GDPR Art. 13(1)(e) requires disclosure of recipients or categories of recipients — which maps directly onto the first-party/third-party distinction in cookie usage. When third-party cookies are listed alongside first-party cookies in an undifferentiated table, users cannot assess the cross-site tracking implications. Third-party cookies set by Google or Meta persist across every site where those providers' scripts run; first-party cookies are domain-scoped. ePrivacy Art. 5(3) consent must be informed about this distinction because the scope of data access differs materially. CCPA §1798.135 similarly requires disclosure of whether personal information is 'sold or shared' with third parties — a concept that maps directly onto third-party cookie tracking.
Severity rationale
Info because the failure is a presentational gap in an existing policy rather than an active tracking violation, but it reduces the quality of the informed consent obtained and limits users' ability to understand the privacy implications of third-party processing.
Remediation
Split the cookie policy table into two sections using the thirdParty field from COOKIE_REGISTRY. Add explanatory prose about what third-party tracking means for cross-site data collection.
// app/cookies/page.tsx — two-section layout
<section>
<h2>First-Party Cookies</h2>
<p>Set directly by {siteHostname}. Not shared with other domains.</p>
{/* COOKIE_REGISTRY.filter(c => !c.thirdParty) */}
</section>
<section>
<h2>Third-Party Cookies</h2>
<p>
Set by external services loaded on our pages. These providers may also
collect data on other sites where their scripts run. Each provider is
subject to its own privacy policy.
</p>
{/* COOKIE_REGISTRY.filter(c => c.thirdParty), include provider + privacyPolicyUrl column */}
</section>
Filter COOKIE_REGISTRY by thirdParty: true | false and render the provider's privacy policy URL as a link in the third-party table.
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. 13(1)(e) — GDPR — data controller must disclose recipients including third parties
- eprivacy · Art. 5(3) — ePrivacy Directive — distinction between first-party and third-party cookies required for informed consent
- ccpa · §1798.135 — CCPA — sale/sharing of personal information to third parties must be disclosed separately
Taxons
History
- 2026-04-18·v1.0.0·Initial import from cookie-consent-compliance·automated