Spotify · Spotify Platform Rules

OneTrust Cookie Consent SDK on Error Page

Low severity
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What it is

Spotify's error page loads the OneTrust cookie consent management platform and Google Tag Manager, meaning tracking scripts are active even when the requested page fails to load.

Consumer impact (what this means for users)

If tracking scripts collect data on page load before a user has given cookie consent, this could constitute a GDPR violation affecting EU users' right to control their personal data under GDPR Art. 7.

Cross-platform context

See how other platforms handle OneTrust Cookie Consent SDK on Error Page and similar clauses.

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Why it matters (compliance & risk perspective)

Tracking technologies firing on error pages before or alongside consent presentation may not comply with GDPR requirements that consent precede data collection.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: This observation implicates GDPR Art. 6(1)(a) (lawful basis for processing), Art. 7 (conditions for consent), and the ePrivacy Directive 2002/58/EC Art. 5(3) (cookie consent requirement), enforced by EU Data Protection Authorities (DPAs) in each Member State and coordinated by the EDPB. In the UK, UK GDPR and PECR SI 2003/2426 apply, enforced by the ICO. (2)

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Applicable agencies

  • FTC
    FTC has jurisdiction over unfair or deceptive data collection practices affecting US consumers under FTC Act Section 5, including pre-consent tracking.
    File a complaint →

Provision details

Document information
Document
Spotify Platform Rules
Entity
Spotify
Document last updated
April 29, 2026
Tracking information
First tracked
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003270
Document ID
CA-D-00037
Evidence Provenance
Source URL
https://www.spotify.com/us/legal/spotify-platform-rules/
Wayback Machine
View archived versions →
SHA-256
ff3684a4be9f14548d63f56d37a6bf49f452e76bc6768e6d8a091d11bdc666fb
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Spotify | Document: Spotify Platform Rules | Record: CA-P-003270
Captured: 2026-04-27 11:05:33 UTC | SHA-256: ff3684a4be9f1454…
URL: https://conductatlas.com/platform/spotify/spotify-platform-rules/onetrust-cookie-consent-sdk-on-error-page/
Accessed: May 2, 2026
Classification
Severity
Low
Categories
Unknown