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> I don't believe that purely functional cookies require GDPR permission - that's covered by "provide services to the user". It's the ones which are functionality to third parties not the user which are the problem.

Ah, I didn't realize that. Well, that does sound much more reasonable.

Actually the ICO page itself presents a great example: if you go to https://ico.org.uk/for-organisations/guide-to-data-protectio... you get:

> Necessary cookies

> Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.

> Analytics cookies [toggle On/Off]

> We'd like to set Google Analytics cookies to help us to improve our website by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone. For more information on how these cookies work, please see our 'Cookies page'.

The implication is that a consent dialog would not be required if they weren't using Google Analytics or any other third-party.

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