Kate joined Miele X in September 2022 as a Consent Manager, with a background in corporate, business and data protection law. “I’m originally from Russia, but I worked in a consultancy in Amsterdam, where I got exposure to European privacy law,” she recounts. “It was something that I hadn’t really experienced before, and it made me passionate about protecting people’s private information.”

She explains that most users don’t understand how online tracking is based on cookies. “They just see this cute word ‘cookie’ and accept it. Yet, if you combine all the data points from different sources and cross-reference them, you can learn a lot about someone based on their online activities.” She’s quick to point out that Miele takes customer data and preserving people’s privacy very seriously, and limits the processing of personal data.

Reyhan’s background is in web analytics project management, analysis and consent management consultancy in the US. He says this exposed him to organisations who just wanted to “hoover up” people’s data, which always frustrated him. “Working for an organisation like Miele that has respect for the customer is so different.”

Ethical, privacy friendly and transparent

Kate explains how her role at Miele X reflects this respect for customers. “I call myself a cookie girl! My work revolves around managing all the consent banners, cookie policies and privacy policies across all of our domains. That means I connect different stakeholders – from the legal department to the tracking team – to ensure that we implement the tracking we want to do in an ethical, privacy friendly and transparent way.”

They’ve both been heavily involved in implementing the OneTrust platform as a cookie compliance solution. Reyhan describes how this links into Miele’s focus on privacy: “OneTrust brings together many aspects of the cookie banner, allowing us to effectively convey to customers what we're doing in a way that's brief and unobtrusive.” He says it’s about cooperation with the user, rather than harvesting personal data.

Preparing to prepare

To prepare for the implementation, Kate took on the daunting task of trying to update the master wording for all the cookie notices across a large number of Miele web domains. “This was really preparation for introducing the new platform,” she says. “The master wording describes data collection by certain vendors.” She points out that many vendors don’t publish much about the data they collect, so she had to surf developer blogs and articles to get the information. She also worked with a technical privacy specialist who was doing technical audits of different use cases on the Miele websites to identify cookies that were not covered by existing notices.

Kate needed to investigate each of the cookies identified during the audit. Using the findings from the technical audits and information collected across different resources, she was able to update cookie notices for all the relevant countries. After each update, she included an overview of the tracking on each domain in a central repository, so there was a single source for this information. “I call it a cookie notice inventory, and we couldn’t have started to prepare without it,” she says. “It gave us a centralised view over all of the domains, so we were ready for the tool that would help us keep it that way.”

Implementing the platform

Deploying a new cookie compliance platform had been in the pipeline at Miele for a while, and it was Reyhan’s job to make it happen. “It involved a lot of familiar tasks for me – project management, implementation and many of the technical aspects. I had to look at who needed to be involved, what we wanted to do and what we could actually do.” That meant working with different teams to get things right and to fix any problems quickly.

Kate worked with Miele stakeholders in different countries to manage expectations for the rollout. This involved gathering country specific requirements, getting the translations, and chasing legal decisions on content. “I had to facilitate decisions about legal details, so we were able to use the platform to centralise not only the approach to consent management, but also the domains themselves.”

A more agile platform

Introducing a new platform was a considerable step up in managing their processes. For Reyhan, the agility of the new platform is a key advantage over the previous one. In the past, when third-party vendors such as Facebook changed how their cookies worked, this had to be managed by the individual Miele country teams. Now, he says, Miele X has a single point where they can enter everything for each cookie on their website, including translations into a large number of different languages. He adds that it also enables them to provide more compliant solutions, quicker.

For Kate, the real benefit is that it’s made her role more straightforward. As an example, she says that before, if she had a cookie that needed to go live, she had to create a request for each country. “But now,” explains Reyhan, “Kate just sends me a file with the cookie we want to add, plus the list of countries we want to add it to, and the translations in the various languages, and I can do that myself. I just update that cookie definition in one spot and then publish it, and it goes everywhere.”

He adds that another positive change is the way the cookie banner appears on the webpage. The old banner wouldn’t allow users to interact with the site until they accepted or rejected cookies. But, Kate says, the new banner is at the bottom of the page, so you can keep scrolling the website and it won’t block your view of the page, ensuring that consent is given freely.

Reyhan says this not only improves the user experience, but it also gives Miele X more accurate information on how many site visitors are accepting or rejecting cookies. “We used to only get that information if they opted into analytics. If they rejected all, we didn’t know they existed. The new platform allows us to see how many people visit the site and who opts into marketing or analytics cookies, which we couldn’t be confident of before.”

He’s also enthusiastic about the new functionality that allows Miele X to continually improve. He says they’ve already shortened the legal text to make it easier for users to understand, and rearranged the accept and reject buttons to encourage more people to accept cookies. But he’s keen to point out that Miele aims to be ethical in how it approaches this. “Many sites have the accept and reject buttons in different colours to point customers where they want them to go, but we don’t do that – ours have the same prominence and are the same colour. It’s about getting the balance right and doing this in an ethical way. We want the information, but we want to gather it responsibly.”

Making a difference

Kate says a lot of people in Miele are excited about the new platform. And Reyhan points out that they’re continuing to look at introducing it to even more countries. “Ideally, we want it to be the one-stop shop for every Miele-owned domain,” he says.

He adds that building something that will stand the test of time is really satisfying. “As a consultant, I was only on a client project for maybe a couple of months and then I was gone,” he says. “At Miele X, we’re all working together to accomplish a goal and that’s a breath of fresh air for me.”

For Kate, the project emphasised that Miele doesn’t compromise on privacy. “Like many lawyers, I went into law to help people by making the world a better and more just place. So being part of a company where you don’t have to compromise on that is great. I honestly feel I’m making a difference every day.”