As per the Google Analytics Terms of Service, you are not allowed to send Personally Identifiable Information (PII) into your reports – even if you have explicit permission from your visitors to collect it. Essentially Google does not want it as doing so would put a huge legal responsibility on it.
But what defines personal data…?
Obviously name; email address; street address, telephone number, national ID numbers constitute etc. constitute personal data.
However, be aware of the non-obvious data points that may at first appear benign, such as a visitor’s gender, age, language, type of car owned, demographic group etc. These in isolation are harmless – they do not identify an individual. However just like a jigsaw, stitch them together and pretty soon you can build up the identity of who that person is.
So you need to be careful…!
As a good general rule, collect only the data you need in order to segment your visitor traffic into your marketing personas. If the business is asking for more of the non-obvious “personal” type of information, ask your stakeholder to justify their request in terms of the GDPR risk. Then put that proposal to your Data Protection Officer (DPO).
BTW, every organisation within the EU now has to assign a DPO that is legally responsible for the data an organisation collects. It may be you!
If you have a website function that collects PII into your back-end system e.g. a contact form or transactional website, contact your web development team to ensure no personal information is being sent to Google Analytics. You may get a reassuring answer of: “Of course not”. But GDPR compliance means you must to have a process in place to verify and confirm it on a regular basis.
Route out PII with Verified Data
The Verified Data tool uses artificial intelligence algorithms to not only be smart about finding PII issues (often they are a small fraction of the total volume of data), but can also do this in multiple languages. Uniquely, Verified Data automatically checks the following Google Analytics reports for signs of any personal information:
- PII Within URLs
- PII Within Events
- PII Within Campaign Parameters
- PII Within Custom Dimensions
- PII Within E-commerce Affiliation
There are many different types of personal data that Verified Data searches for, and simultaneously in multiple languages. The types are at listed at https://verified-data.
How to deal with historically captured personal information
Essentially all routes lead to the deletion of data, and at present this remains very blunt from Google.
PII comes in many shades, but for blatant abuse i.e. deliberate collection of personal information collected over a long period, expect the possibility of losing your GA property or even your account!
For a specific issue, Google deletes the date range effected. So for example a serious breach happening each day, even if low level (which mostly these things are), can mean ALL data from the effective date range being deleted.
Have a problem with PII collection? Follow these steps:
- If your analytics is deployed via are a GTM, use the customTask method in the following post to stop any PII being collected. This technique used is important to follow because it works at the point of data capture i.e. before the data is collected. That can be a real life/career saver because if you collecting PII and then attempting to filters this out in your Google Analytics it is too late! You will fail compliance because the data has already been sent and is therefore already logged in the Google cloud…
- Because of the significant risk of losing data, once you have strong governance in place set up a separate “clean” property within Google Analytics to run alongside the original PII polluted one. This mitigates your risk should your original property have to be deleted.
Essentially anyone can make a mistake and the GDPR is not there to police the internet – rather it is there to ensure organisations have a process in place to spot mistakes and fix them quickly. The key is for you to regularly audit your data so that small mistakes do not become major catastrophes. Verified Data automates the entire auditing process for you.