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Stephane Hamel
Digital marketing & analytics shaped by data governance, privacy and ethics | Educator · Speaker · Consultant
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March 15, 2022
Q) Would you consider the gclid from #googleads as a personal identifier? Is this id in campaigns traceable back to an individual/Google account? R) “(GCLID) is a parameter passed in the URL with ad clicks, to identify the campaign and other attributes of the click associated with the ad for ad tracking and campaign attribution.” But . . . what “other attributes”? [1] If we take it at face value, the GCLID seems harmless as it is just a random ID. And we know, from their help page, that (so far) Google considers IP addresses and pseudonymous cookies and advertising IDs NOT to be personal data . . . [2] But . . . considering the use of GCLID extents tracking across site boundaries and allow Google to track individuals, I would consider it personal data. Oh! Not that YOU, as a marketer, can track it back to an individual user . . . but THEY (Google) can and are doing it, as demonstrated by the ability to do attribution or create retargeting campaigns. . . Furthermore, if you require consent to use marketing cookies, it seems to me receiving such an ID should also be part of the consent mechanism (i.e., as reference [3] suggest): “You shouldn’t track the session’s landing page URL until the user has either allowed or denied consent.” Something else to make tracking more complex then it is now! So I would err on the side of cautiousness and consider it to be #NoConsentNoTracking What do you think? #digitalmarketing #digitalanalytics #GoogleAnalytics #dataethics #dataprivacy #GDPR #eprivacy References in comment.
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March 15, 2022