Google Analytics is installed on over 30 million sites, so it’s no understatement to say millions are waiting with bated breath for clarification on whether Google Analytics is CCPA compliant.
That said, there are still steps you need to take to be fully compliant, which are detailed below.
The information pertains specifically to Google Analytics browser/website tracking - not to Google’s Firebase SDK, a tool for in-app analysis. If you're concerned how GA is impacted by GDPR too, we also have a GDPR Google Analytics Compliance Guide.
Please note, we are not a law firm. Please view this as informational, not legal advice.
The California Consumer Privacy Act is a digital privacy law going into effect January 2020. For a detailed overview, read our CCPA summary. Its key highlights are:
Google Analytics is a free website tool that collects anonymized data on individuals; aggregates it; and provides reports on where users came from, what pages they looked at, and so on.
Integrating with GA involves adding a JavaScript tag or updating a Tag Manager. These tags drop first-party browser cookies that include a randomly-generated ClientID.
While GA’s tags don’t collect PII like email address or name, the CCPA defines PII to include such persistent IDs as this ClientID. Many companies also use the UserID feature, which involves sending internal, anonymized IDs for more accurate tracking. Plus, the tracking tag sends Google the user’s IP Address, which is considered PII under the CCPA too.
Your privacy policy will need to outline the new California consumer rights: the right to notice, access, opt-out, request deletion, and get equal services.
It must also describe what information you collected, sold, and/or disclosed since January 1, 2019, as well as why you did it and how.
Since using GA involves collecting and sending PII to Google, this is info you must disclose in your privacy policy. There’s no specific template for doing so, but one option is:
"We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie "(_ga)" with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have - or ask us to delete any GA data - please delete your "_ga" cookies, reach out to us via this form, and/or install the Google Analytics Opt-Out Browser Add-On."
Indeed's privacy policy offers another way to present the information:
What’s more difficult is figuring out how to honor that request from a technical standpoint. Even this is doable, though, and below lists multiple ways to access or delete their GA data. Fortunately the law gives you some breathing room - you have 10 days to acknowledge the request and 45 days to comply.
First, ask the user to provide their Google Analytics ClientID. To find this, they’ll need to go to their browser’s settings and manually look at what cookies are stored. They should find one named "_ga", which is the Google Analytics cookie, and within it is a string like "GA1.2-2.318596131.1556642125".
The user’s ClientID are the numbers before and after the final period (in this case, "318596131.1556642125"). If they have multiple "_ga" cookies on their browser, they should send all of the ClientIDs.
If you are relying on UserIDs instead of ClientIDs (the differences are here), then you must grab the ID yourself (for instance, if you know their email and have their UserID tied to it).
Next, use Google's User Explorer Report to pull any data associated with this ClientID or UserID, and then send that user this information.
Alternatively, you could use Google's User Activity API to pull the data. The API Response will look like:
Alternatively you could use Google's User Deletion API and their ClientID/UserID to delete any data Google has on them.
Without doing this step, Google would store that user's data for 26 months, violating the CCPA deletion request. So you must manually delete their data via one of these steps should they request it.
While you are at it, you could also direct them to some additional privacy controls that Google offers, including limiting ad personalization and auto-deletion of data.
As a reminder, CCPA is an opt-out law. Meaning, if a user never requests to be excluded, you can legally continue sharing, using, and selling their data.
From two different angles the answer looks to be "no". Those reasons are:
The CCPA is explicitly against selling PII. Their definition of “sale” includes “selling, renting, releasing, disclosing...personal information to a third party for monetary or other valuable consideration”.
With Google Analytics you are not making money from selling this PII (which, again, is just IP Address and a randomly-generated anonymous ID). While one could argue that insights gleaned from website analytics has value, without a true transactional quid pro quo, this seems like a stretch. In other words, if a user opts-out of data selling, it doesn’t apply to GA cookies, and you can continue using Google Analytics without penalty.
Beyond that, the CCPA allows companies to use PII to provide needed business services. One of their examples is using PII to “audit consumer interactions”. As GA measures how users interact with your site, it appears website analytic tools fall under this business purpose - meaning that, like above, GA tracking would not fall under the purview of an opt-out.
This is totally fair. Nobody wants a class-action lawsuit. Plus, respecting your users’ privacy should be a default, not something you skirt around thanks to technicalities.
If you want to take the safer route, here are steps you should take:
For instance, if you are sending internal UserIDs to Google, make sure they are anonymized and not actual PII, like an email. Also check that you aren’t appending PII to URLs, such as "/confirm?email=phenry@" after a form fill-out, as they would be sent to GA.
Google has multiple resources for this, including a guideline on avoiding PII and its privacy control settings. Some steps you could take (based on how draconian you want to be) are:
_ IP Anonymization - This removes the last octet of the IP Address before it’s sent to Google (aka 123.456.789.555 becomes just 123.456.789.0, which helps anonymize who it is) _ Reduce Data Retention Length - By default, Google Analytics stores data tied to an ID for 26 months. You can change this to 14 months in Admin → Tracking Info → Data Retention if you wanted to be more strict (the lowest option available)
_ Turn 'Reset on New Activity' off - In the same spot as above, there is a toggle called 'Reset on new activity'. While this seems to be privacy-focused, it really just extends how long you track them, as every new time they visit your site, the 14 month retention period resets _ Sign DPA - Go to Admin → Account Settings and accept the Data Processing Agreement created for the GDPR, if you haven’t already. This is very important to do _ Data Deletion Requests - Monitor your Data Deletion Requests tab in Admin. Google will flag any instances where it finds PII, and you’ll need to delete them as needed _ Disable Demographics and Interests Reports - Under Admin → Property Settings → Advertising Features, turn this off to prevent Google from making reports around user info _ Turn Off Data Sharing - With Google Analytics, a lot of information is shared with other services. If you go into Account Settings -> Data Sharing, you can turn off these settings
_ Unlink Google Ads / Ad Exchange - If you use Adwords/Adsense/Google Ads Manager, you may have set up linking between the two platforms. Under Admin --> Product Linking, you can turn this off, further limiting what data leaves GA (though this would impact your ad _ Turn off Remarketing & Ad Reporting - Under Admin → Tracking Info → Data Collection, you could turn off Remarketing and Advertising Reporting Features, an additional way to limit what's shared _ Limit the Session Settings time - Under Tracking Seetings --> Session Settings, you can edit the timeout time for individual sessions and campaigns. For instance, if you set the session timeout to 5 minutes, that means that after five minutes of inactivity, that SessionID on the user is no longer tied to anything _ Reduce Cookie Expiration Time - Unless cleared, the "_ga" cookie lasts on the user’s browser for 24 months. Fortunately, you can set this expiration period to whatever you want via the "cookieExpires" parameter in the GA tag. For instance, hardcoding it to "0" turns it into a session-based cookie, and the ClientID will expire when they exit the site
If a user opts out of data selling, and you want to honor that CCPA request by blocking Google Analytics tracking for them, you can:
No fear - we also have you covered there. Please read our GPDR & Ad Tech and our GDPR & Google Analytics articles for info about the GDPR.
Our LGPD & Ad Tech and LGPD & Google Analytics articles offer more info about Brazil's LGPD.
Likewise, we have articles on PDPA & Ad Tech and PDPA & Google Analytics.
To use Google Analytics and stay CCPA compliant, you'll need to:
Of course, further clarifications could change these guidelines, and we’ll update the article if that happens!
