Professional Documents
Culture Documents
(GCS - LCS) (External) Consent Playbook EU (En) - Go - Consent-Playbook
(GCS - LCS) (External) Consent Playbook EU (En) - Go - Consent-Playbook
Consent
Playbook
for EU
user consent
Proprietary + Confidential
Modules
01
Module I:
Adapting to the
evolving ads
ecosystem
Module I: Adapting to the evolving ads ecosystem Proprietary + Confidential
Google has been investing in the teams, technology, processes, and safeguards to meet increasing
regulations, including the way we collect and process consent. Products, privacy and end-user
protections and practices will continue to evolve to meet regulatory requirements in the EU and beyond.
The ePrivacy Directive (Directive 2002/58/EC) (also nicknamed the “Cookie Directive”) provides rules on
storing and accessing data on a users’ device, such as browser cookies.
In 2018, The General Data Protection Regulation (GDPR) entered into force, having far reaching changes
for businesses that offer goods and services online to users in the EEA (European Economic Area). Among
other things, GDPR called for a legal basis for all processing
of personal data of which end-user consent played a prominent role.
[NEW] The Digital Markets Act (DMA) is a new piece of legislation designed to regulate large online
platforms operating in the EEA. The legislation will start being enforced in March 2024. We have always
believed in offering people and businesses choice and control, and competing on the merits of our services.
The DMA will require Google and other companies to make various changes to the way their products and
services work.
In order for the Google tools that advertisers and publishers use to grow their businesses and measurement
(or monetization, for publishers), audience, predictive modeling, and AI advertising tools to keep working as
desired, there are some additional steps that our advertisers may need to take in the coming months due to
evolving privacy expectations for valid consent under existing laws in the EU, as well as new digital
regulations coming into force, such as DMA.
Module I: Adapting to the evolving ads ecosystem Proprietary + Confidential
Advertisers need to enable or upgrade consent mode in order to maintain measurement features
like conversion tracking for websites and apps, and personalization features like targeting certain
audiences. Conversion modeling helps give advertisers a representative view of performance, more
efficient campaign optimization and bidding, and accurate, privacy-centric safe measurement in
instances when users do not consent to their data being shared with Google for advertising
purposes.
Advertisers should implement the following steps before March 2024 to preserve audience features.
Determine the best way to Ensure banner is Implement Verify your implementation
obtain consent, either configured to collect user consent mode via one and compliance via status
through one of the consent and meets EU of the following: and diagnostic tooling in
Consent Management User Consent Policy ● Partner CMP integration your Ads accounts.
Platform (CMP) Partners - (EUUCP) requirements. ● Manual implementation (Coming soon!)
recommended - or through in-page or
in-house solution. in-app code
Follow the decision tree on the next page to learn about your individual next steps.
Module I: Adapting to the evolving ads ecosystem Proprietary + Confidential
Are you tracking conversions and/or using Customer Match and remarketing lists from EEA traffic?
Check with your Google account manager if CMPs and consent mode may be relevant in your market. This
No
playbook focuses on the EEA region.
We recommend working with one of our Consent Management Platform (CMP) Partners to implement
No a consent banner.
Go to Module II to learn more about consent and Consent Management Platforms.
Ensure your consent banner is compliant with the EUUCP. If you are working
Partner CMP with a partner CMP from this list, work with your CMP to make necessary
updates to your banner.
Yes
Ensure your consent banner is compliant with the EUUCP. If you are working
Non-partner CMP
with a non-partner CMP or use an in-house solution to obtain consent
or In-house
go to this section to learn more about potential updates needed.
Move on to step 3 for more guidance on how to work with consent mode.
Yes No
Are you onboarding user data through online or offline methods? Have you already implemented consent mode?
Have you already implemented Go to step 4 Are you working or willing Congratulation!
consent mode? to work with a partner You are done!
CMP from this list?
There’s no action to take
to maintain measurement
No Yes No Yes for apps and websites.
No Yes No Yes
Follow your CMP’s instructions to configure a banner that is compliant with EUUCP and implement the latest
version of consent mode. Find a CMP implementation overview here.
Learn more about consent mode, conversion modeling and its benefits in Module III.
Congratulations! You are done! You have taken necessary action to maintain measurement for apps and websites.
You want to implement consent mode with a non-partner CMP or in-house solution
Make sure you have configured a banner that is compliant with EUUCP.
Learn more about consent mode, conversion modeling and its benefits in Module III and implement the latest
version of consent mode via in-page code for web or in-app code for apps. You may want to read about the two
types of consent mode, particularly in relation to Google Analytics 4. Learn more about consent mode
and Google Analytics 4 here, and about in-page and in-app code implementation.
If you are working with remarketing audiences, remember to pass back consent signals for cookies and advertising
personalization and consider adopting customer match if not using it already.
Upgrade consent mode with a non-partner CMP or in-house solution to obtain personalization consent
Make sure you have configured a banner that is compliant with EUUCP.
To pass back consent signals for cookies and advertising personalization you have to upgrade to the latest version
of the consent mode API via the in-page / in-app code implementation. Learn more about in-page and in-app code.
Congratulations! You are done! You have taken necessary action to obtain personalization consent
to work with audiences.
Note: You will likely see some change in reporting and remarketing based on consent rates/behaviors.
In most cases conversion modeling can help to recover conversions.
Proprietary + Confidential
02
Module II:
Consent
overview
Module II: Consent Overview Proprietary + Confidential
Additionally, the data unlocks insights into how users behave on a site. In turn, websites and business
have a better chance to meaningfully engage with those users.
1 BCG / Google, “Consumers Want Privacy. Marketers Can Deliver.” January 21, 2022.
2 Google/Ipsos, France, Germany, Netherlands, Sweden, U.K., Privacy by design: the benefits of putting people in control, n=10,001, online
participants aged 18-70, July 2022.
Module II: Consent Overview Proprietary + Confidential
At Google, we partner with many CMPs. They will help you manage consent banners and direct the
consent management process, which begins when a user lands on your website and makes a consent
choice on a CMP banner. The CMP then communicates that choice to the Google tag via Consent
Mode, and the tag adjusts its behavior accordingly.
In house banners
If you already have a consent solution in place without using a CMP Partner, It’s important to ensure that it
complies with all local regulations. For example, if you advertise to users in the EEA with Google, your banner
should comply with the EUUCP.
Google cannot give legal guidance on what a consent solution should look like. Backend changes
should follow guidance for websites and apps.
Proprietary + Confidential
03
Module III:
Consent mode
Introducing consent mode
Case study
Module III: Consent mode Proprietary + Confidential
A user navigates to your Consent mode will tell When the user does not With modeling, the most
website or app and Google whether a user consent, no identifying accurate data will be
indicates consent status has given permission to information will be passed surfaced in your account
(for ads and/or analytics use cookies/device IDs to Google. Instead, to enable better reporting
storage, ad user data, for ads and analytics. conversion modeling will and optimization.
and ad personalization). leverage Google AI to
solve for unknowns in the
customer journey for more
comprehensive reporting
and optimization.
Conversion reported
*based on a basic implementation; an advanced configuration will use non-identifying, cookieless pings.
Module III: Consent mode | Introducing consent mode Proprietary + Confidential
Further, where advertisers see less data in their Google Ads or Google Analytics
account due to users’ consent choices, the use of consent mode means that
65%
Google measurement can be adjusted accordingly based on the Google AI
modeling of ad click to conversion journey.
For users who do not consent to their data being shared with Google for On average, consent mode
measurement purposes, conversion modeling helps give advertisers a recovers around 65% of
ad-click-to-conversion journeys
representative view of performance, more efficient campaign optimization
lost due to user cookie
and bidding, and more accurate, privacy-safe measurement by modeling
consent choices.1
for lost conversions.
Google is committed to protecting the confidentiality and security of your data. We'll keep your data
confidential and secure using the same industry-leading standards we use to protect our own users’ data.
We only report aggregated conversions. You can read more about how we use your consent mode data.
EEA presence Consent banner & Google tag (Web) & Google
consent mode Analytics for Firebase SDK (Apps)
Consent mode is recommended Consent mode is a mechanism for Must either use Google tag or Google
to customers with an EEA presence passing consent signals to respect Tag Manager (web) or Google Analytics
or a region with opt-in consent user consent choices made on a for Firebase SDK (apps). Legacy tags are
regulations. consent banner within website or not supported.
within an app.
More resources: About consent mode | How Google uses consent mode data
Module III: Consent mode | Introducing consent mode Proprietary + Confidential
When a user doesn’t consent, Conversion modeling uses Using observable, Modeled conversions will be
consent mode, ensures that Google AI to quantify the consented user journeys, integrated directly in your
Google tags do not read or write relationship between attribution paths will be Google Ads campaign
cookies for advertising or consented and modeled for the reports and used for bidding
analytics purposes. unconsented users. unconsented journeys. and optimization.
More resources: About consent mode modeling | About modeled online conversions
Module III: Consent mode | Introducing consent mode Proprietary + Confidential
To learn more about consent mode and Google Analytics 4 review this section.
*When tags are blocked due to consent choices, no personal data is collected, and conversion modeling in Ads
is based on a general model. The models use features such as browser type, conversion action type, country,
and other high-level, non-identifying variables.
Please note: Enhanced conversions for web is available for Google Ads and Google Analytics 4.
Browser restrictions
Normal path Regulatory impact 1
impact
Cookie settings
Accept
Accept all Reject all
selection
Conversion
is reported
Conversion
is reported
Enhanced conversions for web and consent mode go hand-in-hand to provide a more
accurate picture of performance:
● Consent mode solves for regulatory changes and enhanced conversions for web solves for browser changes.
● Consent mode models for unconsented conversions that cannot be observed; enhanced conversions observes
conversions that are not observed today on certain browsers.
● Both solutions can help to get more accurate reporting, modeling, and bidding and both will be reported in the
conversion column in your Google Ads account.
● Enhanced conversions for web data is never sent for non-consented customers.
1
Regulations such as GDPR and ePrivacy are not new and obtaining consent is not a new requirement. Learn more.
Module III: Consent mode | Introducing consent mode Proprietary + Confidential
Please ensure you are using the latest version of Google Analytics (GA4)
to benefit from the latest privacy centric features.
When you implement a consent banner for your website or app, Analytics will be missing data for users who decline
consent. There are two ways modeling in Google Analytics 4 can help to fill data gaps.
Data being modeled based on user and session metrics can help answer questions like:
● How many daily active users do I have?
● How many new users did I acquire from my last campaign?
● What is the user journey from landing on my website to actually making a purchase?
● How many of my site visitors are based in Germany vs. the UK?
● What is the difference in user behavior between mobile vs. web visitors?
Pre-requisites:
Consent mode Consent mode for At least 1,000 events At least 1,000 daily
enabled across all web pages: tags must load per day with users sending events
pages of your site / before the consent dialog analytics_storage='deni with analytics_storage
screens of your app. appears, and Google tags ed' for at least 7 days. ='granted' for at least 7
must load in all cases, not of the previous 28 days.
only if the user consents.
(Advanced implementation)
Behavioral modeling in Google Analytics 4 requires the advanced implementation of consent mode,
meaning that the Google tag must load in all cases, not only when the user consents.
More resources: [GA4] About modeled conversions | [GA4] Behavioral modeling for consent mode | Manage user consent
Module III: Consent mode Proprietary + Confidential
WEB
Get started:
Implementing consent mode for web
Implementation overview:
Validate implementation
Validate the consent mode implementation in Google Ads by checking the consent mode status and your consent mode
impact results 7 days later in the “Diagnostics” tab.
Module III: Consent mode | Get started: Implementing consent mode for web Proprietary + Confidential
WEB
Consent Management Platforms allow for simpler implementation due to an integration with Google
consent APIs. Find an overview of the CMP partners here.
Please note: We always recommend to reach out to your CMP partner for more details
on how to enable consent mode with your specific platform.
In order to enable the Google consent mode, go to Menu > CMPs > Edit > Other
Consentmanager
settings and enable Google Consent Mode. Learn more here.
Implement Cookie Information’s GTM template OR insert the initial config script in the
Cookie Information A/S
head section of your website. Learn more here.
Navigate to the OneTrust UI > Geolocation Rules, select the rule group to configure,
OneTrust
and enable the Google consent mode setting. Learn more here.
Checkbox "on" the consent mode option within the Didomi UI. Follow the developer
Didomi
instructions to properly configure it. Learn more here.
Go to Usercentrics Admin Interface -> Configuration -> CMP Settings, enable Google
Usercentrics
Consent Mode and click Save. Learn more here.
log in to your Sirdata CMP account -> configuration section -> editing icon -> select
Sirdata "Update add-ons". Move the slider of the "Activate Google Consent Mode" option.
Learn more here.
You can enable consent mode in the wizard under Statistics – Configuration. Learn
Complianz
more here.
WEB
● Implementing consent mode manually will require changes to your code. Including your developer
early on is highly recommended.
● If you use Google Tag Manager, we recommend creating your own template using Tag Manager
consent APIs. This example is available to reference as a starting point.
● If you use gtag.js, you will have to manually add consent code to each page of your site as direct
commands or in a custom HTML snippet, since users can update consent preferences at any point
on your site.
● You can decide between the basic and the advanced implementation (learn more here). If you want
to utilize behavioral modeling in Google Analytics 4, you have to use the advanced implementation.
Find advanced
implementation instructions
and examples in the
developer guide.
Looking for server-side Tag Manager implementation guidance? Use this developer guide for more information.
Module III: Consent mode | Get started: Implementing consent mode for apps Proprietary + Confidential
APP
Get started:
Implementing consent mode for apps
Implementation overview:
Have you made sure to check the three factors for a successful
implementation?
Find implementation
instructions and examples
in the developer guide.
WEB
Status Meaning
Your consent mode is implemented but you have not yet met the thresholds for conversion modeling.
Consent mode
The click threshold for conversion modeling is 700 ad clicks over 7 days for a domain x country grouping.
is implemented
You will be able to see modeling uplift impact results about 7 days after you implement consent mode.
Consent mode is
Modeling uplift numbers on a domain x country level will be shown for 4 weeks after the publish time,
implemented and
which starts once you meet volume and modeling thresholds for a country. After the impact table with
modeling is active
your modeling uplift goes away, this status validates that consent mode is working.
WEB
The 4-week window of modeling impact results has passed. Modeling uplift data is only shown for 4 weeks after
2
the modeling start date.
3 We don’t have enough data to model for that domain and country.
The domain x country has active conversion modeling, but the uplift is below 1%, which is the minimum
4
threshold to appear in your impact results.
If the uplift data of all or one of your largest geographic segments is missing, then there may be an
implementation issue. Double-check your consent mode implementation by using the instructions for Google tag or
consent configuration with Google Tag Manager.
Reason Solution
When consent mode isn't detected on 100% of your pages you can experience gaps
Consent mode isn't detected
in modeling. Make sure your: (1) Google tag is present on all pages. (2) Consent state
on some pages
is set on all pages. (3) Default or update call is firing before Google tags fire.
The ad click consent rates Your consent management platform (CMP) may be best positioned to advise you on
we detect from a domain are optimizing consent rates. Make sure your: (1) Default and update calls are set in the
too low to receive full right order. (2) Default or update call is firing before Google tags fire. (3) Banner
modeling benefits meets regulatory guidance for your region.
Unblock tags to fire cookieless Cookieless pings have no ad click identifier sent if data redaction = true. The pings
pings for users that don't can provide more accuracy and improve modeling results. Learn more about how to
consent to conversion tracking manage consent settings.
Case study
Boosting HALLHUBER’s The challenge
As a premium fashion brand, HALLHUBER has been offering a unique
performance with more selection of clothing, bags, shoes, and accessories for over 40 years.
The increased activity of many retailers (especially during peak
comprehensive seasons), market challenges, and the client's strong
The approach
Premium women’s fashion retailer HALLHUBER wanted to respect its users' consent choices and at the
EMEA - Germany • hallhuber.com same time retain an accurate picture of its ad performance. The
company implemented consent mode on its websites in Germany,
Agency Name: PIA Media
Austria, and Switzerland to recover conversion loss due to user cookie
consent choices.
Partnering with PIA Media: PIA Media's ads strategy and technical
understanding of the latest standards helped HALLHUBER close
measurement gaps and increase efficiency.
The results
With more accurate data available through consent mode, HALLHUBER
was able to significantly improve its cost-to-revenue ratio and better
calibrate its campaigns. The retailer experienced a 14% overall increase
in conversions, which led to more qualified and cost-efficient traffic.
Performance Lift
For more information on how to future-proof your measurement with privacy-first solutions visit
ads.google.com/intl/en_us/home/privacy/.
© 2023 Google LLC. All rights reserved. Google and the Google logo are trademarks of Google LLC. All other company and product names
may be trademarks of the respective companies with which they are associated.
Proprietary + Confidential
04
Module IV:
Frequently
asked questions
Module IV: Frequently asked questions Proprietary + Confidential
● Users should be informed (e.g. via a consent banner) that their personal data will be collected and for what purposes
so that they can decide if they agree to the processing or not. Learn more here.
Does consent mode collect personally identifiable data and / or personal data?
● When you enable consent mode, Google products ensure that a visitor’s consent mode state is preserved across the
pages they visit. With the advanced Implementation of Consent Mode, if consent is denied, tags that fire do not store
cookies, instead they communicate a minimum of information about user activity. Consent state and user activity are
then tracked by sending cookieless pings, or signals, to the Google server. With the basic implementation of Consent
Mode, if consent is denied, tags are blocked until consent is granted and no personal data is collected.
● Google is committed to protecting the confidentiality and security of your data. We'll keep your data confidential and
secure using the same industry-leading standards we use to protect our own users’ data. You can read more about
how we use your consent mode data.
● IP address is critical to help advertisers manage user consent settings by region. The tags collect IP address as part
of regular HTTP protocols. For Google Ads and Floodlight systems, the IP address is used to derive user-country, and
immediately deleted upon collection. IP addresses are never saved or stored. Learn more about the tag behavior.
With the basic implementation of Consent Mode, if an advertiser chooses not to send a cookieless ping (tags
blocked/tags do not fire) when ad_storage is denied, IP address, Ad-click Identifiers, URL, 3P Cookies, 1P advertising
Cookies, and Analytics Cookies are not sent to Google.
● Once consent mode is implemented, advertisers will have access to a new tag setting, ad_storage, which controls
cookie behavior for advertising purposes, including conversion measurement and targeting features like
personalization. If a user does not provide consent for ads cookies, the relevant Google tags adjust accordingly and
do not use ads cookies. Without cookies, advertisers are no longer able to directly tie users' ad interactions to
conversions. To help close this gap, we launched conversion modeling through consent mode.
● Consent mode and enhanced conversions for web are two standalone products and are not pre-requisites for each
other, but they work together to help provide a more accurate picture of performance. If consent is granted, enhanced
conversions for web can recover conversions that are being blocked by browser restrictions. If consent is not granted,
enhanced conversions for web will not be used for unconsented users and consent mode will model conversions.
● For customers that do not use Google Analytics, TCF (Transparency & Consent Framework) is an alternative.
Module IV: Frequently asked questions Proprietary + Confidential
Durable Measurement =
Use one tag across Increase reported online Measure offline Use Google Analytics 4 Reach customers and
Use case
your website to conversions that were conversions that came for a variety of use build new audiences
measure effectiveness. missed due to browser from a website lead or cases, e.g. unified user using first-party data.
restrictions on cookies. visitor GCLID-less journeys and improved
without a full data models, leveraging
CRM integration. Google AI.
Single tag solution & Connect offline data to AI-powered Advertisers who adopt
Customer Match with
foundation for Google Ads, for measurement
Benefit
overall increase in
conversions per dolar.2
(1) Advertisers who used tCPA with Enhanced conversions saw a +3.5% uplift in conversion volume at a similar CPC than advertisers who
used tCPA without EC. | Google internal data, Global, 7/2/2021 - 7/28/2021.
(2) Google Internal Data. 2022-2023. Conversions per dollar measured as Conversions / Cost. e.g. Pre Customer Match 10 conversions at
$100 = .1; Post Customer Match application 20 conversions at $150 = .133 -> This is a 34% difference between pre/post CPD