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United Kingdom
United Kingdom
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CASE STUDY
“In some areas of research there were also significant time savings. You get to what you are looking for more quickly, which all goes to the value of the product.”
Harper McleodAccess all documents on Flash cookies
Flash cookies meaning
Published by a LexisNexis Information Law expert
What does Flash cookies mean?
Flash cookies are data files created by Adobe Flash Player—also called local shared objects (LSOs)—stored on a user’s device to support Flash-based functions such as video, interactive graphics and games. Although Flash reached end‑of‑life in 2020 and is blocked by most browsers, LSOs may still appear on legacy sites, intranets and archived content.
The term is descriptive rather than statutory. For legal purposes, LSOs are “similar technologies” to cookies under the UK Privacy and Electronic Communications Regulations 2003 (PECR) and Ireland’s ePrivacy Regulations (SI 336/2011). Storing or accessing them generally requires prior consent unless strictly necessary for a service expressly requested by the user, alongside transparency obligations.
Flash cookies can track similar parameters to HTTP cookies and, because they are tied to a specific Flash feature, can also record feature‑level usage (for example, how much of a video was watched and when viewing stopped). They may store larger amounts of data and are managed outside standard browser controls, increasing compliance risk.
Where LSOs directly or indirectly identify an individual, the UK GDPR/GDPR applies in addition to PECR/ePrivacy. Treatment is broadly consistent across England and Wales, Scotland, Northern Ireland and Ireland. Audits, cookie policies and consent mechanisms should account for any residual use...
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View the related Practice Notes about Flash cookies
PRACTICE NOTES
EU cookies and similar technologies: ePrivacy Directive, GDPR interplay, consent, exemptions, enforcement, audits and reform
STOP PRESS This Practice Note reflects the present legislative landscape; however, be aware that some aspects will be affected by the Digital Omnibus proposals issued on 19 November 2025 under the Commission’s ‘simplification’ programme. For further details, see Practice Note: EU Digital Omnibus—tracker. This Practice Note explores the law governing the use of cookies and related technologies in the EU, covering the following: Types of cookies and related technologies ePrivacy Directive and cookies Responsibility for compliance Consent Clear and comprehensive information Exemptions EU GDPR and cookies Territorial scope Intranets Sanctions and enforcement Cookie audits Reform Resources and guidance Cookies are small data files placed on a user’s computer, phone or tablet. They enable an online service, such as a website, to recognise an individual user and retain particular information about them, such as login credentials, the contents of shopping baskets and site preferences. They are also widely used to direct advertising...
21 May
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PRACTICE NOTES
Ireland: Cookies and Similar Technologies—ePrivacy Regulations 2011, GDPR interplay, consent and information duties, exemptions, third-party cookies, DPC enforcement, audits, intranets, territorial scope, reform
This Practice Note examines the law on the use of cookies and similar technologies in Ireland It addresses the following: types of cookies and comparable tracking technologies SI No 336/2011 European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (Ireland) SI No 336/2011 (IRL) (the ePrivacy Regulations (IRL)) and cookies responsibility for compliance consent clear and comprehensive information exemptions Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (EU GDPR) and cookies territorial scope intranets sanctions and enforcement cookie audits reform resources and guidance Cookies are small text files stored on a user’s device, such as a computer, smartphone or tablet. They let an online service recognise a particular user, and...
21 May
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