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• How to not process any personal data with Matomo and what it means for you

  22 avril 2018, par InnoCraft

  Disclaimer : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to explain how to not process any personal data with Matomo in order to avoid going through the GDPR compliance process with Matomo analytics. This work comes from our interpretation of different sources : the official GDPR text and the UK privacy commission : ICO resources. It cannot be considered as a professional legal advice. So as GDPR, this information is subject to change. GDPR may be also known as RGPD in French, Spanish, Portuguese, Datenschutz-Grundverordnung, DS-GVO in German, Algemene verordening gegevensbescherming in Dutch, Regolamento generale sulla protezione dei dati in Italian.

  Are you looking for a way to not process any personal data with Matomo ? If the answer is yes, you are at the right place. From our understanding, if you are not processing personal data, then you shouldn’t be concerned about GDPR. Our inspiration came from this official reference :

  “The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes.“

  In this blog post we are going to see how you can configure Matomo in order to not process any personal data and what the consequences are.

  Which data is considered as personal according to GDPR ?

  From : eur-lex.europa.eu

  (1) “‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’) ; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person ;”

  (30) “Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.”

  So according to your Matomo configuration, it may leave some traces within the following data :

  1. IP addresses
  2. Cookies identifiers
  3. Page URL or page titles
  4. User ID and Custom “personal” data
  5. Ecommerce order IDs
  6. Location
  7. Heatmaps & Session Recordings

  Let’s see each of them in more detail.

  1. IP addresses

  IP addresses can indirectly identify an individual. It can also give a good approximation of an individual’s location.

  IP addresses are therefore considered as personal data which means you need to anonymize them. To do so, a feature is available within Matomo, where you can anonymize the IP. We recommend you to anonymize at least the last two bytes :

  

  See our configuration guide for more information

  What are the consequences of using this feature ?

  When applying IP anonymization on two bytes, you will no longer be able to see the full IP in the UI.

  Moreover, there is a small chance that 2 different visitors with the same device and software configuration will be identified as the same visitor if the anonymised IP address is the same for both.

  2. Cookies

  It is not clear for us yet if all cookies are considered equal under GDPR. At this stage it is too early to make a definite decision.

  Did you know ? Matomo lets you optionally disable the creation of cookies by adding an extra line of code to your tracking code see below.

  

  See our configuration guide for more information

  What are the consequences of using this feature ?

  Matomo is using a few first party cookies, and the following cookies may hold personal data :

  • _pk_id : contains a visitor id used to identify unique visitors
  • _pk_ref : to identify from where they came from

  If Matomo cannot set cookies, it will use a technique called Fingerprint. It is based on several metadata such as the operating system, browser, browser plugins, IP address, browser language ; just to name a few to identify a unique visitor. As this feature is less accurate than the one using cookies, the number of visitors and visits will be affected.

  3. Page URLs and page titles

  URLs are not mentioned within the official GDPR text. However, we know that according to the different CMS you use, some of them may have URLs including personal identifiers.

  For example :

  

  As a result, you need to find a way to anonymize this data.

  There are several ways you can perform this action according to your website. If your website is adding the personal data through query parameters, you can define a rule to exclude them from Matomo.

  If the personal data are not included within query parameters, you can use the “setCustomURL” feature and write your code as follow :

  

  See our developer documentation for more information

  If you are also processing personal data within the title tag, you can use the following function : “setDocumentTitle”.

  What are the consequences of using this feature ?

  By anonymizing the URLs containing personal data, some of your  URLs will be grouped together.

  4. User ID and custom personal data

  User ID is a feature (a tracking code needs to be added) which allows you to identify the same user across different devices.

  A User ID needs a corresponding database in order to link a user across different devices, it can be an email, a username, a name, a random number… All those data are either direct or non direct online identifiers and are therefore under the scope of GDPR.

  It will be the same situation if you are using custom variables and/or custom dimensions in order to push personal data to the system.

  To continue using the User ID feature but not recording personal data, you can consider using a hash function which will anonymize/convert your actual User ID into something like “3jrj3j34434834urj33j3”.

  Alternatively, you can enable the feature “Anonymise User IDs”. This feature will be available starting in Matomo 3.5.0 :

  

  What are the consequences of using this feature ?

  Under GDPR, User ID is personal data. Anonymizing the User ID using a hash function or our built-in functionality make the User Id pseudo-anonymous, which means it can’t be easily identified to a specific user. As a result, you will still get accurate visits and unique visitors metrics, and the Visitor Profile, but without tracking the original User ID which is personal data.

  5. Ecommerce order IDs

  Order IDs are the reference number assigned to the products/services bought by your customers. As this information can be crossed with your internal database, it is considered as an online identifier and is therefore under the scope of GDPR. As for User ID, you can anonymize order IDs using our built-in functionality to Anonymise Order IDs (see section 4. about User Id).

  What are the consequences of anonymizing order ID ?

  It really depends on your former use of order IDs. If you were not using them in the past then you should not see any difference.

  6. Location

  Based on the IP address of a visitor, Matomo can detect the visitors location. Location data is problematic for privacy as this technology has become quite accurate and can detect not only the city a visitor is from, but sometimes an even more precise position of a visitor.

  

  In order to not leave any accurate traces, we strongly recommend you to enable the IP anonymization feature. Next, you need to enable the setting “Also use the anonymized IP address when enriching visits”. You find this setting directly below the IP anonymization. This is important as otherwise the full IP address will be used to geolocate a visitor.

  

  What are the consequences of anonymizing location data ?

  The more bytes you anonymize from the IP, the more anonymized your location will be. When you remove two bytes as suggested, the city and region location reports will not be as accurate. In some cases even the country may not be detected correctly anymore.

  7. Heatmaps & Session Recordings

  Heatmaps & Session Recording is a premium feature in Matomo allowing you to see where users click, hover, type and scroll. With session recordings you can then replay their actions in a video.

  Heatmaps & Session Recordings are under the scope of GDPR as they can disclose in some specific cases (for example : filling a contact form) personal data :

  

  To avoid this, Matomo will anonymize all keystrokes which a user enters into a form field unless you specifically whitelist a field. Many fields that could contain personal data, such as a credit card, phone number, email address, password, social security number, and more are always anonymized and not recorded.

  See our configuration guide for more information

  Note that a page may still show personal information within the page as part of regular content (not a form element). For example an address, or the profile page of a forum user. We have added a feature which allows you to set an HTML attribute “data-matomo-mask” to anonymize any personal content shown in the UI.

  What are the consequences of using this feature ?

  Mainly, you will not be able to see in plain text what people are entering into your forms.

  What should you do with past data ?

  Once more, we have to say that we are not lawyers. So do not take our answers as legal advice. From : ec.europa.eu/newsroom/article29/document.cfm ?doc_id=50053

  “For example, as the GDPR requires that a controller must be able to demonstrate that valid consent was obtained, all presumed consents of which no references are kept will automatically be below the consent standard of the GDPR and will need to be renewed.”

  Our interpretation is that, if you were previously relying on consent, unless you can demonstrate that valid consent was obtained, you need to get the consent back (which is almost impossible) or you need to anonymize or remove that data.

  To anonymize previously tracked data, we are actively working on a feature to do just that directly within Matomo. Alternatively, you may also set up the deletion of logs after a certain amount of time.

  We really hope you enjoyed reading this article. GDPR is still on the go and we are pretty sure you have a lot of questions about it. You probably would like to share our vision about it. So do not hesitate to ask us through our contact form to see how we are interpreting GDPR at Matomo and InnoCraft.

  The post How to not process any personal data with Matomo and what it means for you appeared first on Analytics Platform - Matomo.

• How to make Matomo GDPR compliant in 12 steps

  3 avril 2018, par InnoCraft

  Important note : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to briefly show you where Matomo is entering into play within the GDPR process. This work comes from our interpretation of the UK privacy commission : ICO. It cannot be considered as professional legal advice. So as GDPR, this information is subject to change. We strongly advise you to have a look at the different privacy authorities in order to have up to date information.

  The General Data Protection Regulation (EU) 2016/679, also referred to RGPD in French, Datenschutz-Grundverordnung, DS-GVO in German, is a regulation on data protection and privacy for all individuals within the European Union. It concerns organizations worldwide dealing with EU citizens and will come into force on the 25th May 2018.

  The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It includes cookies, IP addresses, User ID, location, and any other data you may have collected.

  We will list below the 12 steps recommended by the UK privacy commissioner in order to be GDPR compliant and what you need to do for each step.

  The 12 steps of GDPR compliance according to ICO and how it fit with Matomo

  As mentioned in one of our previous blog post about GDPR, if you are not collecting any personal data with Matomo, then you are not concerned about what is written below.

  If you are processing personal data in any way, here are the 12 steps to follow along with some recommendations on how to be GDPR compliant with Matomo :

  1 – Awareness

  Make sure that people within your organization know that you are using Matomo in order to analyze traffic on the website/app. If needed, send them the link to the “What is Matomo ?” page.

  2 – Information you hold

  List all the personal data you are processing with Matomo within your record of processing activities. We are personally using the template provided by ICO which is composed of a set of 30 questions you need to answer regarding your use of Matomo. We have published an article which walks you through the list of questions specifically in the use case of Matomo Analytics. Please be aware that personal data may be also tracked in non-obvious ways for example as part of page URLs or page titles.

  3 – Communicating privacy information

  a – Add a privacy notice

  Add a privacy notice wherever you are using Matomo in order to collect personal data. Please refer to the ICO documentation in order to learn how to write a privacy notice. You can learn more in our article about creating your privacy notice for Matomo Analytics. Make sure that a privacy policy link is always available on your website or app.

  b – Add Matomo to your privacy policy page

  Add Matomo to the list of technologies you are using on your privacy policy page and add all the necessary information to it as requested in the following checklist. To learn more check out our article about Privacy policy.

  4 – Individuals’ rights

  Make sure that your Matomo installation respects all the individuals’ rights. To make it short, you will need to know the features in Matomo that you need to use to respect user rights (right of access, right of rectification, right of erasure…). These features are available starting in Matomo 3.5.0 released on May 8th : GDPR tools for Matomo (User guide).

  5 – Subject access requests

  Make sure that you are able to answer an access request from a data subject for Matomo. For example, when a person would like to access her or his personal data that you have collected about her or him, then you will need to be you able to provide her or him with this information. We recommend you design a process for this like “Who is dealing with it ?” and check that it is working. If you can answer to the nightmare letter, then you are ready. The needed features for this in Matomo will be available soon.

  6 – Lawful basis for processing personal data

  There are different lawful basis you can use under GDPR. It can be either “Legitimate interest” or “Explicit consent”. Do not forget to mention it within your privacy policy page. Read more in our article about lawful basis.

  7 – Consent

  Users should be able to remove their consent at any time. By chance, Matomo is providing a feature in order to do just that : add the opt-out feature to your privacy policy page.
  We are also offering a tool that allows you optionally to require consent before any data is tracked. This will be useful if a person should be only tracked after she or he has given explicit consent to be tracked.

  8 – Children

  If your website or app is targeted for children and you are using Matomo, extra measures will need to be taken. For example you will need to write your privacy policy even more clear and moreover getting parents consent if the child is below 13. As it is a very specific case, we strongly recommend you to follow this link for further information.

  9 – Data breaches

  As you may be collecting personal data with Matomo, you should also check your “data breach procedure” to define if a leak may have consequences on the privacy of the data subject. Please consult ICO’s website for further information.

  10 – Data Protection by Design and Data Protection Impact Assessments

  Ask yourself if you really need to process personal data within Matomo. If the data you are processing within Matomo is sensitive, we strongly recommend you to make a Data Protection Impact Assessment. A software is available from the The open source PIA software helps to carry out data protection impact assessment, by French Privacy Commissioner : CNIL.

  11 – Data Protection Officers

  If you are reading this article and you are the Data Protection Officer (DPO), you will not be concerned by this step. If that’s not the case, your duty is to provide to the DPO (if your business has a DPO) our blog post in order for her or him to ask you questions regarding your use of Matomo. Note that your DPO can also be interested in the different data that Matomo can process : “What data does Matomo track ?” (FAQ).

  12 – International

  Matomo data is hosted wherever you want. So according to the location of the data, you will need to show specific safeguard except for EU. For example regarding the USA, you will have to check if your web hosting platform is registered to the Privacy Shield : privacyshield.gov/list
  Note : our Matomo cloud infrastructure is based in France.

  That’s the end of this blog post. As GDPR is a huge topic, we will release many more blog posts in the upcoming weeks. If there are any Matomo GDPR topic related posts you would like us to write, please feel free to contact us.

  The post How to make Matomo GDPR compliant in 12 steps appeared first on Analytics Platform - Matomo.

• How to measure the performance of a newsletter (or any email) with Matomo

  19 décembre 2017, par InnoCraft

  To be able to grow your business, it is crucial to track all your marketing efforts. This includes all newsletters and emails that you share with people outside of your business. Otherwise, you won’t be able to know which of your daily efforts are yielding results.

  Are you wondering if it is possible to track the performance of an emailing campaign in Matomo (Piwik) efficiently ? Would you like to know if it is technically easy ? No worries, here is a “How to” tutorial showing you how easily you can track an emailing in Matomo properly.

  Different tracking levels for different needs

  There are many things that you may be interested to track, for example :

  

  1. How many users opened your email
  2. How many users interacted with the links in your email
  3. How many users interacted on your website through your email

  Let’s have a look at each of these levels.

  Step 1 – Tracking email and newsletter openings in Matomo

  Tracking email openings requires to add an HTML code to your newsletter. It works through what we call a tracking pixel, a tiny image of 1×1 that is transparent so the user will not be able to see it.
  In order to install it, here is an example of what this code looks like :

  <img src="https://piwik.example.com/piwik.php?idsite=YOUR_PIWIK_WEBSITE_ID&rec=1&bots=1&url=https%3A%2F%2Fexample.com%2Femail-opened%2Fnewsletter_XYZ&action_name=Email%20opened&_rcn=internal%20email%20name&_rck=newsletter_XYZ" style="border:0;” alt="" />

  The Matomo tracking pixel explained

  The above URL is composed of the following URL parameters which are part of our Tracking API :

  • idsite : Corresponds to the ID of the website you would like to track.
  • rec : You need to have rec=1 in order for the request to be actually recorded.
  • bots : Set it to 1 to include all the connections made to this request, bots included.
  • url : corresponds to the URL you would like to display in Matomo (Piwik) every time the email is opened.
  • action_name : This is the page name you would like to be tracked when the email is opened.
  • _rcn : The name you would like to give to your campaign.
  • _rck : The keyword you may like to use in order to summarize the content of your newsletter.

  You may have noticed some special characters here such as “%20”, “%2F”. That’s because the URL is encoded. We strongly recommend you to do so in order for your tracking not to break. Many tools are available on the web in order to encode your URLs such as https://www.urlencoder.org/.

  If you would like to access the previous tracking code easily, keep in mind that you can always find the tracking code generator within the “Matomo admin panel → Tracking code” :

  

  You can find more information about it on our guide at : How do I track how many users open and read my newsletter emails (using a pixel / beacon) ?

  As a result, the information will be pushed as following for any user who opens your email :

  

  To not bias your regular page views on your website with newsletter openings, we recommend tracking newsletter openings into a new website.

  Tracking even more data : the user ID example

  You can go deeper in your URL tracking by inserting other parameters such as the user id if you have this information within your emailing database. One of the main benefit of tracking the User ID is to connect data across multiple devices and browsers for a given user.

  You only need to add the following parameter &uid=XXX where XXX equals the dynamic value of the user ID :

  

  Make sure that UID from your emailing provider is the same as the one used on your website in order for your data to be consistent.

  Important note : some email providers are loading email messages by default which results in an opening even if the user did not actually open the email.

  Step 2 – Measure the clicks within your emailing

  Tracking clicks within an email lets you know with which content readers interacted the most. We recommend tracking all links in all your emails as a campaign, whether it is a newsletter, a custom support email, an email invoice, etc. You might be surprised to see which of your emails lead to conversions and if they don’t, try to tweak those emails, so they might in the future.

  Tracking clicks This works thanks to URL campaign tracking. In order to perform this action, you will need to add Matomo (Piwik) URL parameters to all your existing link URLs :

  • Website URL : for example “www.your-website.com”.
  • Campaign name : for example “pk_campaign=emailing”. Represents the name you would like to give to your campaign.
  • Campaign keyword : for example “pk_keyword=name-of-your-article”. Represents the name you would like to give to your content.
  • Campaign source : for example “pk_source=newsletter”. Represents the name of the referrer.
  • Campaign medium : for example “pk_medium=email”. Represents the type of referrer you are using.
  • Campaign content : for example “pk_content=title”. Represents the type of content.

  You can find more information about campaign url tracking in our “Tracking marketing campaigns with Matomo” guide.

  Here is a sample showing you how you can differentiate some links in a newsletter, all pointing to the same URL :

  

  Once you have added these URL parameters to each of your link, Matomo (Piwik) will clearly indicate the referrer of this specific campaign when a user clicks on a link in the newsletter and visits your website.

  Important note : if you do not track your campaigns, it will result in a bad interpretation of your data within Matomo (Piwik) as you will get webmail services or direct entries as referrer instead of your newsletter campaign.

  Step 3 – Measure emailing performances on your website

  Thanks to Matomo (Piwik) URL campaign parameters, you can now clearly identify the traffic brought through your emailing. You can now specifically isolate users who come from emails by creating a segment :

  

  Once done, you can either have a look at each user specifically through the visitor log report or analyze it as a whole within the rest of the reports.

  You can even measure your return on investment directly if goals have been defined. In order to know more about how to track goals within Matomo (Piwik).

  Did you like this article ?

  If you enjoyed reading this article, do not hesitate to share it around you. Moreover, if there are any topics you would like to write us about in particular, just drop us an email and we will be more than happy to write about it.

  The post How to measure the performance of a newsletter (or any email) with Matomo appeared first on Analytics Platform - Matomo.