Released in April 2018, the GDPR consent flow is presented to hundreds of millions to over a billion users across Meta’s platforms (Facebook, Instagram, WhatsApp, Messenger) who reside in the European Economic Area (EEA), the UK, and Switzerland, as well as user who happen to move to these regions where GDPR applies. This consent was part of a broader compliance effort requiring users in the EU and other GDPR regions to review and manage their data settings, including targeted ads, face recognition, and third-party data sharing.
In early versions of the GDPR consent flow, the primary button (styled prominently in blue) was labeled “Accept and Continue”, while the “Manage Settings” option were secondary in UI hierarchy. User research and regulatory scrutiny indicated that this UI nudged users toward opting in rather than providing a balanced choice. This design was flagged as a dark pattern by privacy advocates and regulators, who argued that it subtly influenced users into opting in. Many users did not fully understand what they were consenting to due to dense legal text. Some felt that opting out was hidden or required significantly more effort compared to opting in. GDPR regulations require freely given, informed, and unambiguous consent, which meant the design had to enable a genuinely neutral choice.
As Lead Product Designer, I refined the GDPR consent flow, focusing on third-party data (3PD) consent. The challenge was balancing opt-in retention with concerns about dark patterns, particularly the “Accept & Continue” CTA. Collaborating with Privacy’s Consent and Notifications team and UXR, I iterated on designs and conducted research to ensure users clearly understood the consent request and its implications. I secured Consent Steerco approval for the Agency headline and polar question above CTAs, now a standard in the Consent UI Guidelines. Additionally, I introduced a research-backed “sense of place” design pattern for blocking consent experiences, now a template for FB and IG.
This design solution was estimated to positively impact Meta’s iRev growth by approximately 0.98% to 1.97%.
