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.
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.
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.
"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."
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
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:
_gacookies on their browser. This would delete their cookie’s ClientID
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.
|Caveat||Why it's important|
|It's a one-time request||Asking for data deletion is not the same as opting-out of data selling (they are two different rights). So if a user asks for data deleted, it’s fine if the GA cookie drops again the next visit|
|PII is tied to a household||For whatever reason, the CCPA associates PII to a household, not to an individual. So if a user requests deletion, you would technically have to follow the same steps above for everyone in their house. This isn’t feasible, so we’ll see if that rules changes over time|
|User verification||The law says that businesses cannot provide data to individuals (the right to access) without authenticating the request, but it’s unclear how to verify the person is who they say they are|
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
https://email@example.com after a form fill-out, as they would be sent to GA.
_gacookie lasts on the user’s browser for 24 months. Fortunately, you can set this expiration period to whatever you want via the
cookieExpiresparameter in the GA tag. For instance, hardcoding it to
0turns 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:
|Use a third-party consent management platform||Work with a CMP that prompts for consent on page load, has a toggle option for Google Analytics, and can then block the GA tag if no consent is given.|
|Add code to the GA tag||Follow Google’s User Opt Out instructions. Similar to above, this would involve dynamically identifying the user and adding specific code for their sessions|
|Dynamically drop GA tag||Have the GA tag appear only for users that haven’t opted-out. You would have to write custom code that references an exclusion list before dropping the GA script in the page’s `head` tag|
|Browser extension||Have them install the Google Analytics Opt-Out browser extension. This prevents GA from dropping a _ga cookie|
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!
Chris has worked in ad tech for over twelve years in a variety of roles - giving him customer support, PM, and marketing perspectives from both the advertiser and publisher sides. He's the VP of Marketing at Kevel.