You Ask, I Answer: Google Analytics and Data Privacy?

Jim asks, “We’ve actually gotten pushback internally for using GA because of data privacy. Ever come across this?”

Plenty of times. There are situations in which Google Analytics would not meet regulatory requirements. Google Analytics is not HIPAA compliant; the only industry certification for security it possesses is ISO 27001. And while no PII/SPI/PHI is ever supposed to be in GA, we know it happens. So best practice, if you are working in an environment that mandates a certification GA doesn’t have (like TS/SCI), you have to use something else.

Watch the video for a discussion of options.

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Machine-Generated Transcript

What follows is an AI-generated transcript. The transcript may contain errors and is not a substitute for watching the video.

In today’s episode, Jim asks, we’ve actually gotten pushback internally for using Google Analytics because of data privacy.

Have you ever come across this? Yes.

plenty of times there are situations where Google Analytics does not meet regulatory requirements for data privacy, data security, things like that.

For the average business, as long as you’ve implemented correctly, it’s fine.

For businesses that require an ISO certification, like ISO to 7001, which is a cybersecurity standard, Google Analytics is fine.

for situations where you have sensitive personal information or protected health information, for example, Google Analytics is not fine.

And the reason for this is that there’s no way that you can prove the compliance to some of those standards, with Google as the data processor and the data living on remote servers that you don’t have control over.

And that is, and remains one of the biggest challenges for organizations that want to be able to use web analytics in a highly sensitive environment.

Generally speaking, a big part of compliance issues with Google Analytics, in general, is implementation.

If you are inadvertently passing protected information of any kind, even if it’s just personally identifiable information, you are creating a data security problem.

And you are also technically violating the terms of service for Google Analytics itself.

One of the prohibitions for using the software is that you do not attempt to store any personally identifiable information within Google Analytics.

So no email addresses, no names, no social security numbers, nothing that would create essentially a legal hazard for Google, as well as your organization, those things cannot be stored in there.

So a big part for all organizations is making sure that you have implemented and audited it on a regular and frequent basis to make sure you’re not pushing data in there that contains that information.

The biggest culprit are forms that do not use the HTTP POST protocol, there’s two protocols with forms GET and POST, get puts the data from the form into the URL of a form.

And then that gets processed on your website somewhere, post puts it in a different mechanism, that is not the URL.

And when you put personally identifiable information in the URL of the site, by default, you are putting it into Google Analytics.

And that’s where a lot of the trouble happens when you’re talking about getting data in there.

Now, there are other ways to put data into Google Analytics, the measurement API, the measurement protocol, custom dimensions, custom metrics, things like that.

But those typically require conscious intent, you have to want to do that to build it into your API calls, or to build it into a custom dimension or metric that you set up as a trigger in Google Tag Manager.

And so most companies, following basic compliance, wouldn’t do that.

It’s just not something they would do.

Whereas most companies don’t necessarily audit their forms to see what mechanism they’re sending.

And so you can be accidentally sending that data in.

So one of the critical things to do if you are using Google Analytics, regardless of your data privacy policies, is to audit your forms, audit your website, and make sure you’re not putting any obvious data into Google Analytics by accident.

Now, Google Analytics is not HIPAA compliant.

Google says so in the documentation on its website, it does not meet the standard for HIPAA, the health information Portability and Accountability Act.

As I said, the only certification has is ISO to 7001, the information security certification.

And so if you have higher restrictions, like FERPA, for example, HIPAA, top secret, special compartmented information, you absolutely should not be using Google Analytics, for pages that are involved in in those environments.

Now.

If you’re in, for example, a healthcare environment, you can have your public website running Google Analytics, right.

And then like a patient portal where people log in hmm that’s that’s a place where you don’t want to have it running.

You want to have a different solution in those cases.

Same for you know, finance or education.

If you’ve got you know, regulations like FERPA, for example, that governs education.

Your colleges website can absolutely run Google analyze Right, because you should not be collecting personally identifiable information on your public college website, on your student portal, on your academic portal on your faculty portals should not be running unless you have audited them, and made sure they are not passing sensitive information into Google Analytics.

Now, if you want to have web analytics in those situations, you need to have something that runs locally on servers that you own an audit and can pass it an auditor’s test.

And then you would run an open source web analytics package that runs on those servers that, obviously because you own them, and you own where the data is stored, you are then, in compliance with many of those things, the package that I recommend, is an open source package called matomo.

matomo runs, like I said, locally on a server that you set up, designate and run.

And it can be tuned to be, however strict or lenient, you want it to be with the collection of data.

But in those environments where you have, you know, user data, PII SPI, Ph I, that’s the kind of software you want to run, you want to make sure that they are kept separate, that you don’t use the same Tag Manager containers.

In fact, for servers that run sensitive information, I would not use Tag Manager at all I would use matomo has a version of its own Tag Manager that again, runs on a server that you control.

And keep those things separate, you’ll have to build separate reporting, you’ll have to go through the hoops of keeping those systems totally separated.

But in doing so you’re meeting the compliance requirements, as long as the server you’re running it on, of course, meets those compliance requirements as well.

So matomo, on a locally run server will get you web analytics without running into the data privacy issues.

Now, for organizations that don’t meet those regulatory requirement, but don’t have those regulatory requirements, they are not HIPAA organizations are not healthcare or education or finance.

And you’re just getting pushback internally.

A big part of that, again, goes to configuration and setup and doing audits.

And if you can demonstrate to your stakeholders, yeah, we’ve done an audit, we’ve validated that we’re not sending any data to Google that we shouldn’t be, then I think you can make a pretty strong case, that’s fine to use in those situations where you’re not going to be collecting sensitive data.

But it’s really important to do that audit.

There are any number of very straightforward techniques to do do that kind of auditing.

A lot of it involves you if you’ve got Google Analytics already running, just looking through the data you’re collecting, as well as being on the website itself and measuring to make sure that forms behave properly, that you can’t see something obvious in the URL like Oh, look, there’s my name, just submit the form.

That’s a pretty clear indicator that you’re not doing something correctly.

But it’s a good question.

It’s an important discussion, because not enough organizations think about privacy.

Not enough organizations think about data privacy, and where the data lives, and what data we’re sending and to whom.

So some good questions.

What I would do is contact your legal counsel and get a list of what you are required to comply with, and then use that to decide Can I make Google Analytics do this? Or is this something that Google Analytics simply cannot do? And if the latter is the case, and you have to use a different solution? Got follow up questions, leave them in the comments box below.

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