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A privacy friendly way to use Google Analytics
The Dutch Privacy Regulator (CBP) has published instructions on how to use Google Analytics in a privacy friendly way by following four steps. Analytics is Google’s service that collects website statistics like visitor traffic and page views. In order to generate this data, small text files are stored on the end users computer; the so called analytical cookies.
With its instruction the CBP seems to anticipate the proposed amendment of article 11.7a of the Dutch Telecommunications Act (Tw). This amendment comprises a more flexible approach on the conditions for placing analytical cookies. As soon as the new article 11.7a Tw is in force, prior consent is no longer a condition for the use of analytical cookies with no or limited impact on the privacy of end users.
Nevertheless, analytical cookies still process personal data. The CBP notes that an IP address is still to be categorised as personal data, even when the last three numbers have been deleted; an option Google Analytics offers. End users need to be informed on the processing of their personal data. It is however arguable if this duty to inform also requires, as the CBP recommends, to specify all measures taken according to the instructions.
The instructions (in Dutch) are available here.