Technology 3 minutes read

One signal instead of a thousand banners

Global Privacy Control records the objection once in the browser and sends it to every site visited. A Berlin court held in 2022 that it has to be honoured – raising a question many banners do not answer.

The idea is old and simple: instead of making a decision on every individual website, it is set once in the browser and sent along automatically. Technically that happens through an extra line in every request – as readable for the website as the language setting.

Why the second attempt turned out differently

Do Not Track (2009)
Global Privacy Control (2020)
A request with no legal anchor
Designed as the exercise of a statutory right
One browser switched it on by default – devaluing it as an expression of will
Has to be switched on deliberately and is therefore a decision
Was honoured by practically nobody and largely removed in 2019
Enforced by regulators in California, confirmed by a court in Germany

The Berlin Regional Court decision

In 2022 the Berlin Regional Court held that such a signal is a valid objection under Article 21 GDPR. The reasoning is brief and persuasive: the Regulation prescribes no particular form for an objection, and in the context of information society services it expressly names automated means as a permissible route.

An uncomfortable consequence follows for practice: showing a banner although the signal is already present asks about something already answered – while ignoring the answer that is there.

What implementing it involves

Three steps on the server side

  1. Read the signalOne line in the request, as easy to read as the preferred language.
  2. Adopt it as the defaultEvery non-essential purpose stays off. The banner either does not appear or appears with that default.
  3. Give a local decision precedenceAnyone who explicitly agrees for this site has made a later and more specific decision – that one prevails.
The effort is small – reading a signal is easier than designing a banner. The reason it rarely happens is economic: the signal almost always arrives as a refusal.

The last point deserves attention because it is often built the wrong way round. The signal is a general default, the decision in the banner a specific one for this one site. The more specific and later decision prevails – but only where it was actually made. Simply assuming it because the banner appeared would be the old mistake in new packaging.

Published 28 September 2026

This article explains general principles and does not replace legal advice on an individual case.

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