The EDPBrecommends as a best practice that consent should be refreshed at appropriate intervals.Providing all the information again helps to ensure the data subject remains well informed about howtheir data is being used and how to exercise their rights.

For example, as the GDPR requires that a controller must be able to demonstrate that valid consentwas obtained, all presumed consents of which no references are kept willautomatically be below theconsent standard of the GDPR and will need to be renewed. Likewise as the GDPR requires a“statement or a clear affirmative action”, all presumed consents that were based on a more impliedform of action by the data subject (e.g.a pre-ticked opt-in box) will also not be apt to the GDPRstandard of consent.