The short answer here is that it depends on what you’re doing with the raw data. “Monitoring” under the GDPR is referred to within the context of profiling:
In order to determine whether a processing activity can be considered to monitor the behaviour of data subjects, it should be ascertained whether natural persons are tracked on the internet including potential subsequent use of personal data processing techniques which consist of profiling a natural person, particularly in order to take decisions concerning her or him or for analysing or predicting her or his personal preferences, behaviours and attitudes.
So for example, if you were using Google Analytics (even with IP the anonymization feature in place), you can at least tell the region of users. This information coupled with user account details such as a company email address and /or age information can be used to infer further details such as average income, about an individual user, which can then be used in profiling.
Alternatively, if the raw anonymized Google Analytics data isn’t coupled with individual user data and is instead used statistically to give you general information about how users are using the website, then this is not considered “monitoring” behavior.
How iubenda can help
For more information on privacy policies click here
For more information on our Cookie Solution click here.
You can read more about our GDPR solutions or read all our compliance solutions here or click below to start generating.