Privacy Policy Requirements for Google Analytics Remarketing

Are you using Google Analytics Advertising Features? If you are, you’ll need to make sure your Privacy Policy explains exactly which features you’re using and why you are using them. Last week, Google notified Google Analytics users about this, and action should be taken as soon as possible. This is due to the changes in how Google Analytics’ Remarketing option works, by enriching it with cross-device data available in Adwords and DoubleClick.

How to Check If This Applies To You

If you’re unsure about whether your Google Analytics account is setup to collect data for advertising, there’s an easy way to check. Firstly, go into the admin panel of Google Analytics, then find the Property column and click Tracking Info > Data Collection. You’ll then see two toggles which will indicate if you’re enabling data collection for Remarketing and/or Advertising Reporting Features. If these toggles are enabled (as shown below) then you need to check your privacy policy is fit for purpose.

Google’s Update Requirement

Your privacy policy should already state that your company uses Google Analytics, however if you have Advertising Features enabled, you must make these options clear. No specific wording has been provided by Google since different countries abide by different privacy laws and regulations. It’s up to you to create the update by considering your company’s unique aspects of data use and following Google’s guidelines. Google requires you to disclose the following information in your privacy policy:

“- The Google Analytics Advertising Features you’ve implemented.
– How you and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
– How visitors can opt-out of the Google Analytics Advertising Features you use, including through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI’s consumer opt-out).
– We also encourage you to point users to Google Analytics’ currently available opt-outs for the web.”

-Taken from Google’s Privacy Policy. Read full policy here

Google is taking this policy requirement seriously, and so should your company. If you don’t update your policy accordingly, you could be infringing on the Data Protection Act.