Do I need a GDPR "coockie" banner if I implement not a unique identifier but only a naive counter?

My web app check a key presence in local storage. Key is the same for all. If it's not found - call /increment api (with no message or data at all) and create one. If it already exists - do nothing. Just like "warrant canary". I like to call it reverse personification.


The GDPR covers information that can be used to identify a person. But a mere counter does not offer this possibility.

Do not link database entries to this cookie. For the GDPR, it does not matter whether personal data is stored directly in the cookie, or is merely indexed by this cookie.

  • But strictly speaking such a counter still reduces entropy of user identity by almost one bit. – SerG Feb 27 '19 at 11:50
  • @SerG: Well, browser identity. And while you can make a point that browser identity can be correlated with user identity, you can't do that with literally one bit. – MSalters Feb 28 '19 at 9:06

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