If you’re a marketer, you’ve probably heard the rumblings of an update to Google Consent Mode. But what exactly is it, and how will it impact you or your clients?
TL;DR: If your business isn’t using Google Ads remarketing to customers in the EEA/UK, you may decide not to bother with Google Consent Mode v2, but by not doing so, you will miss out on capturing conversion modelling data in GA4 and Google Ads.
Why is Google Consent Mode necessary?
It all started way back in 2002 with the EU ePrivacy Directive. This made displaying cookie notices a legal requirement for all websites accessible to users based in the EU. Websites quickly whacked up a cookie banner, most of which forced users to opt in by only providing ‘Accept all’ as an option and considered it job done.
This meant that the vast majority of businesses did not respect the data preferences of users – especially when it came to how their data was being used for advertising purposes. By only having ‘Accept’ as an option, it got around the issue of actually letting a user give consent for their data to be used for marketing purposes. Great for Google and marketers. Bad for the user. And deemed illegal.
Data privacy laws have been evolving at a rapid pace in the last few years. And with it, businesses that collect data have had to adapt quickly to fill the void left by marketing data disappearing, while also ensuring that they adhere to new regulations.
When it comes to collecting marketing data, Google is an absolute beast. However, there are still concerns that it is in violation of data privacy laws because of how it collects information on users from across the web, particularly in the EU. That being said, they are attempting to put measures in place to combat these issues.
Google Consent Mode v1
Google Consent Mode was rolled out in 2020 with the aim of respecting user privacy (though it was very much pushed into this by EU data privacy laws such as GDPR and the ePrivacy Directive, and the decline of third-party cookies), while still being able to collect data for its Google Analytics and Google Ads platforms.
The first iteration of Google Consent Mode had two consent states, both of which relate to how data is collected:
- analytics_storage, which asked the user to consent to their data being used for analytics
- ad_storage, which asked the user if they consent to their data being used for advertising
Typically, this consent is managed via a cookie policy banner on a website. If a user consents, the data will be passed to Google Analytics (GA4) and Google Ads.
With the new Digital Markets Act (DMA) looming, Google knew that it had to take action to beef up Consent Mode. Businesses should make sure they are doing the same when it comes to adhering to data privacy legislation.
Here comes Google Consent Mode v2
As well as the existing analytics_storage and ad_storage consent states, Google Consent Mode v2 has been updated to be more compliant with new data privacy laws specific to collecting data used for advertising purposes which can be used for ad personalisation (i.e. remarketing), rather than just collecting and storing the data.
Google states:
As a part of Google’s ongoing commitment to a privacy-centric digital advertising ecosystem, we are strengthening the enforcement of our EU user consent policy. Advertisers must adhere to the EU consent policy to use ad personalisation. In 2024, our enforcement action will also impact measurement features and apply to data from:
- Websites: Tags that send data to Google
- Apps: SDKs that send data to Google
- Data uploads: Tools to upload data from non-Google sources, such as offline conversion imports or shop sales
The main change in Google Consent Mode v2 is the addition of two more consent states related to how user data is used and shared for advertising purposes: ad_user_data and ad_personalization.
- ad_user_data determines whether personal data is sent to Google (via Google Ads Google Shopping, Google Play) depending on whether or not a user gives consent
- ad_personalization determines whether personal data is sent to Google for Remarketing purposes depending on whether or not a user gives consent
Do I really need to upgrade to Google Consent Mode v2?
If you want to continue to collect data on users based in the EEA/UK for advertising purposes, yes, you most certainly do.
For businesses that fall into this category, they are going to need to review whether or not their current cookie banner is fit for purpose. Here’s why.
Businesses using Google Ads will not be able to utilise EEA user data from March 2024 onwards if they do not meet Google’s standards for compliance. This is a requirement for Google Consent Mode v2. Advertisers using Google Ads who need to make changes to their cookie banner/policy may see a notification in their account warning them of this.
If they do not comply, it will significantly impact the effectiveness of Google Ads campaigns; especially Remarketing and Display campaigns. In fact, non-compliance will result in not being able to collect data for remarketing at all.
What are the differences between Basic and Advanced Google Consent Mode?
There are two types of Google Consent Mode – Basic and Advanced.
With the Basic Google Consent Mode, if a user does not explicitly consent to sharing their data (i.e. does not click ‘Accept’ on a cookie banner), tags are prevented from loading, and therefore, you won’t get any user data sent to Google. As in nothing, nada.
If a user does consent, data that supports conversion modelling in GA4 and Google Ads is also collected.
But if you want to see as much data as possible, implementing Advanced Consent Mode is advisable.
The Advanced Google Consent Mode loads Google tags prior to users giving or rejecting content on the cookie banner and collects data that does not contain personal identifiers/aggregate information about user interactions. These are known as ‘cookieless pings’, and can capture data on country, device, browser, conversion type, and timestamp.
If a user rejects cookies, the tags will adapt their behaviour, and will not pass user data but will send cookieless pings, which can then be utilised for behavioural and conversion modelling on GA4/Google Ads.
Find out more about consent state and tag behaviour here.
What are the benefits of Google Consent Mode v2?
Not only do businesses risk losing the ability to collect data for advertising purposes if they do not comply with the Google Consent Mode v2 requirements, but they will also miss out on modelling data.
Google Consent Mode v2 uses Machine Learning in its Conversion Modelling built on observable data and historical trends against the data of users who have consented to their data being collected.
While not perfect, AI data modelling can help to piece together insights which feed data into conversion paths resulting from ad clicks that would have been completely lost.
Not an ideal solution by any means, but as we move more and more towards a cookieless world, the data we see in analytics tools is going to increasingly be based on AI modelling, rather than actual user data.
What do I need to do?
First of all, cookie banners should be configured to meet these requirements:
- The opt-out (‘no’/’reject’ option) must have the same prominence as the opt-in (‘yes’/’accept’ option) and these choices must be visible to users immediately. It’s also recommended that all buttons are the same size and colour, so that users are not drawn into clicking ‘accept’
- The cookie banner must show a user what is being tracked, and provide them the option to opt out of cookies that they do not wish to pass data to. The cookie policy should also stipulate exactly what data is being tracked, and should be linked to from the cookie banner
- The cookie banner needs to be able to store user consent. This is important in case data privacy regulators come knocking
For websites using a cookie banner provider or cookie management platform (i.e. CookieYes, Cookie Script, Cookiebot), check whether their product is compliant with Google Consent Mode v2, and whether this has been updated automatically, or requires a manual update (i.e. via Google Tag Manager). You may need to enable Consent Mode in the banner settings.
A list of cookie consent management platforms that integrate with Google Tag Manager can be found here toward the bottom of the page.
If you have an in-house solution, you will need to check that the banner provides users with the choice of opting out/changing cookie settings, and complies with Google’s own EU User Consent Policy, as well as the legal requirements from other privacy regulations (GDPR, ePrivacy Directive, DMA).
The deadline for implementing Google Consent Mode v2 is 6 March 2024 – so make sure you have this completed ASAP.
