France: National Commission on Informatics and Liberty opened consultation on draft recommendation on session replay tools

On 25 February 2026, the National Commission on Informatics and Liberty (CNIL) closes the consultation on its draft recommendation on session replay tools. The draft recommendation is addressed to session replay tool providers and website and mobile application publishers. It sets out practical recommendations to ensure compliance with Article 82 of Law No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, the General Data Protection Regulation (RGPD), and Directive 2002/58/EC on Privacy and Electronic Communications. The draft recommendation covers lawful purposes for deployment, consent requirements, actor qualifications under the RGPD, exercise of data subjects' rights, and implementation of the principles of minimisation, limitation of retention periods, and security of processing. It is not exhaustive and carries no regulatory force. It was developed following a consultation phase with representatives of the professions concerned and representatives of civil society.