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Google Analytics and the GDPR: Is It Considered Monitoring Behavior?

⚠️ Important update

Say goodbye to manual IP anonymization. Google Analytics 4 now ensures IP addresses are not stored by default, enhancing your user privacy.

👉 Want to learn more? Check out our Google Analytics 4 overview.

Is Google Analytics and the GDPR? Is It Considered Monitoring Behavior? We’ll take a look at all below 👀

Monitoring behavior

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.

💡 To learn more about which EU cookie consent rules apply on a per-country basis, check out our Cookie Consent Cheatsheet here.

Is Google Analytics compliant with the GDPR?

Several European data protection authorities have found that Google Analytics’ processing of European user data could result in illegally transferring data outside of Europe. Here’s why →

Due in part to this conversation around the use of Google Analytics, Google released Google Analytics 4 in an attempt to address some concerns.

Not sure what privacy laws apply to you?

Take this 1-min quiz to find out! 

How iubenda can help

Regardless of which of the above-mentioned approaches you take, you must meet your disclosure requirements by having accurate and up-to-date information about the data you collect, the purpose, use and third-party processing in your privacy policy. Read more about the GDPR and its requirements here.

Our Privacy Policy Generator is affordable, available in several languages, lawyer crafted, customizable and self-updating (as it’s monitored remotely by our lawyers). It easily allows you to create a beautiful, precise privacy policy. Our 1700+ lawyer-crafted clauses and custom clause option makes it easy for you to comply with even the strictest requirements.


👀 For more information on privacy policies click here

Our privacy policies also comes with the option to include a cookie policy (which is likely necessary if you’re using Google Analytics as under the Cookie Law, whether statistical third-party cookies are exempt from consent requirements may depend on the law of the individual member state )

This also means that our Privacy Controls and Cookie Solution for the Cookie Law will also be useful to you. Our comprehensive Privacy Controls and Cookie Solution simplifies compliance with provisions of the European Cookie Law. It’s an easy to run cookie policy and cookie consent solution (including banner management), that’s fast and does not require heavy investments.

👀 For more information on our Privacy Controls and Cookie Solution, click here.

You can read more about our GDPR solutions or read all our compliance solutions here.

Google Analytics 4

Here’s how to switch to and set up Google Analytics 4 →

See also