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• How to Choose a GDPR Compliant Web Analytics Solution

  2 mars 2022, par Matthieu Aubry — Privacy

  Since the launch of GDPR, one big question has lingered around with uncertainty – is Google Analytics GDPR compliant ? The current GDPR enforcement trend happening across the EU is certainly shedding some light on this question.

  Starting with the Austrian Data Protection Authority’s ruling on Google Analytics and more recently, CNIL (the French Data Protection Authority) has followed suit by also ruling Google Analytics illegal to use. Organisations with EU-based web visitors are now scrambling to find a compliant solution.

  The French Data Protection Authority (CNIL) has already started delivering formal notices to websites using Google Analytics, so now is the time to act. According to CNIL, organisations have two options :

  1. Ceasing use of the Google Analytics functionality (under the current conditions) 
  2. Use a compliant web analytics tool that does not transfer data outside the EU

  Getting started 

  For organisations considering migrating to a compliant web analytics tool, I’ve outlined below the things you need to consider when weighing up compliant web analytics tools. Once you’ve made a choice, I’ve also included a step-by-step guide to migrating away from Google Analytics. This guide is useful regardless of which GDPR compliant analytics provider you choose.

  Before getting started, I recommend that you document your findings against the following considerations while reviewing GDPR compliant Google Analytics alternatives. This document can then be shared with your Data Protection Officer (DPO) to get their final recommendation.

  10 key considerations when selecting a GDPR compliant web analytics tools

  Many tools will claim to be GDPR compliant so it’s important that you do your due diligence and review tools against the following considerations. 

  1. Where does the tool store data ? 

  The rulings in France and Austria were based on the fact that Google Analytics stores data in the US, which does not have an adequate level of data protection. Your safest option is to find a tool that legally stores data in the EU.

  You should be able to find out where the data is stored in the organisation’s privacy policy. Generally, data storage information can be found under sections titled “Subprocessors” and “Third-party services”. Check out the Matomo Privacy Policy as an example. 

  If you’re unable to easily find this information or it’s unclear, reach out to the organisation for more information.

  2. Does the tool offer anonymous tracking ?

  Anonymous tracking comes with many benefits, including :

  • The ability to track visitors without a cookie consent screen. Due to the privacy-respecting aspect of cookieless tracking, you don’t need to worry about the extra steps involved with compliant cookie banners.
  • More accurate data. When visitors deny tracking cookies, you lose out on valuable data. With anonymous tracking there is no data lost as you don’t need consent to track.
  • Simplified GDPR compliance. With this enabled, there are fewer steps you need to take to get GDPR compliant and stay GDPR compliant.

  For those reasons, it may be important for you to select a tool that offers anonymous tracking functionalities. The level of anonymous tracking you require will depend on your situation but you should look out for tools that allow you to :

  • Disable fingerprinting 
  • Disable user profiles 
  • Anonymise data
  • Cookieless tracking

  If you want to read more about data anonymization, check out this guide on data anonymization in web analytics.

  3. Does the tool integrate with my existing tech stack ?

  You’ll want to ensure that a new web analytics tool will play well with other tools in your tech stack including things like your CMS (content management system), eCommerce shop, etc. You should list out all the existing tools that currently integrate with your Google Analytics and check that the same integrations can be re-created with the new tool, via integrations or APIs.

  If not, it could become costly trying to connect your existing tech stack to a new solution.

  4. Does the tool offer the same features and insights you are currently using in Google Analytics ? Or more, if necessary ? 

  Just because you are moving to a new web analytics platform, doesn’t mean you have to give up the insights, reports and features you’ve grown accustomed to with Google Analytics. Ensuring that a new platform provides the same features and reports that you value the most will result in a smoother transition away from Google Analytics.

  It’s unlikely that a new tool will have all of the same features as Google Analytics, so I’d recommend listing out and prioritising your business-critical features and reports. 

  If I had to guess, you probably set up Google Analytics years ago because it was the default option. Now is your chance to make the most of this switch from Google Analytics and find a tool that offers additional reports and features that better aligns with your business. If time permits, I’d highly recommend that you consider other features or reports that you might have been missing out on while using Google Analytics.

  Check out this comparison of Google Analytics vs Matomo to see side-by-side feature comparison.

  5. Does the tool accept Google Analytics data imports ? 

  The historical data in Google Analytics is a critical asset for many businesses. Fortunately, some tools accept Google Analytics data imports so you don’t lose all of the data you’ve generated over time.

  However, it’s important to note that any data you import from Google Analytics to a new tool needs to be compliant data. I’ll cover this more below.

  6. Does the tool provide conversion tracking exports ? 

  Do you invest in paid advertising ? If you do, then tracking the conversions from people clicking on these paid ads is critical in assessing your return on investment. Since sending IP addresses or other personal information to the US is illegal under GDPR, we can only assume that this will also apply to advertising pixel/conversion tracking (e.g., Facebook pixel, Google Ads conversion tracking, etc). 

  As an example, Matomo offers conversion tracking exports so you can get a better understanding of ad performance while meeting privacy laws and without requiring consent from users. See how it works with Matomo’s conversion tracking exports. 

  7. How will you train up your in-house team ? Or can you hire a contractor ?

  This is a common concern of many, and rightfully so. You’ll want to confirm what resources are readily available so you can hit the ground running with your new web analytics tool. If you’d prefer to train up your in-house team, check the provider’s site for training resources, videos, guides, etc.

  If you’d rather hire an external contractor, we recommend heading to LinkedIn, reaching out to your community or asking the provider if they have any recommendations for contractors.

  In addition, check that the provider offers technical support or a forum, in case you have specific questions and need help.   

  8. Does the tool offer self-hosting ? (optional)

  For organisations that want full control over their data and storage location, an on-premise web analytics tool will be the preferred option. From a GDPR perspective, this is also the easiest option for compliance.

  Keep in mind that this requires resources, regular maintenance, technical knowledge and/or technical consultants. If you’re unsure which option is best for your organisation, check out our on-premise vs cloud web analytics comparison breakdown.

  Find out more about self-hosting Matomo.

  9. Is the tool approved by the CNIL for tracking without consent ?

  This is an important step for websites with French users. This step will help narrow down your selection of tools. The CNIL offers a programme to identify web analytics solutions that can be used without tracking consent. The CNIL’s list of recommended web analytics tools can act as your starting point for solutions to review.

  While this step is specific to sites with French users, it can also be helpful for websites with visitors from any other EU country.

  Benefits of consent-free tracking

  There are many benefits of tracking without consent.
  

  For one, it simplifies GDPR compliance and reduces the chances of GDPR breaches and fines. Cookie consent screens have recently been the target for EU Data Protection Authorities because many websites are unknowingly serving cookie consent screens that do not meet GDPR requirements. 

  Yet another benefit, and quite possibly the most important is more accurate data. Even if a website displays a user-friendly, lawful consent screen, the majority of users will either ignore or reject cookie consent. Legally website owners can’t track anything unless the visitor gives consent. So not having a cookie consent screen ensures that every visit is tracked and your web analytics data is 100% accurate. 

  Lastly, many visitors have grown fatigued and frustrated with invasive cookie consent screens. Not having one on your site creates a user-friendly experience, which will likely result in longer user sessions and lower bounce rates.

  10. Does the tool offer a Data Processing Agreement (DPA) ? 

  Technically, any GDPR compliant web analytics tool should offer a DPA but for the sake of completeness, I’ve added this as a consideration. Double check that any tools you are looking at provide this legally binding document. This should be located in the Privacy Policy of the web analytics provider, if not reach out to request it.

  As an example, here’s Matomo’s Data Processing Agreement which can be found in our Privacy Policy under Subprocessors. 

  That wraps up the key considerations. When it comes to compliance, privacy and customer data, Matomo leads the way. We are looking forward to helping you achieve GDPR compliance easily. Start your free 21-day trial of Matomo now – no credit card required.

  Try Matomo Cloud

  A step-by-step guide to migrating from Google Analytics

  Once you’ve identified a tool that suits your needs and your Data Protection Officer (DPO) has approved, you’re ready to get started. Here’s a simple step-by-step guide with all the important steps for you to follow :

  1. Before getting started, you should sign or download the Data Processing Agreement (DPA) offered by your new web analytics provider.

  2. Register for the new tool and configure it for compliance. The provider should offer guides on how to configure for GDPR compliance. This will include things like giving your users an easy way to opt-out of all tracking, turning on cookieless tracking or asking users for consent and anonymizing data and IP addresses, for instance.

  3. Inform your organisation about the change. Whether your colleagues use the tool or not, it’s important that you share information about the new tool with your staff. Let them know what the tool will be used for, who will use the tool and how it complies with GDPR. 

  4. Let your DPO know that you’ve removed Google Analytics and have implemented the new tool.

  5. Update your records of processing activities to include the new tool.

  6. Update your privacy policy. You’ll need to include details about the web analytics provider, where the data is stored, what data is being collected, how long the data will be stored and why the data is being collected. The web analytics tool should readily have this information for you.

  As an example, if you decide to use Matomo as your web analytics tool, we provide a Privacy Policy template for you to use on your site and a guide on how to complete your privacy policy under GDPR with Matomo. Note that these are only applicable if you are using Matomo.

  In addition, if the tool has an opt-out feature, you will also need to put the opt-out into the privacy policy (e.g., when using cookieless tracking).

  7. Now, the exciting part. Add the tracking code to your site by following the steps provided by the web analytics tool. 

  If you’re not comfortable with this step, the provider should offer steps to do this and you can share this with your web developer.

  8. Once added, login to your tool and check to see if traffic is being tracked.

  9. If your tool does not offer Google Analytics data imports or you do not need the historical data in your new tool, go to step 11. 

  To plan for your Google Analytics data migration, you’ll first need to establish what historical data is compliant with GDPR.

  For example, you shouldn’t import any data stored beyond the retention period established in your Privacy Policy or any personally identifiable information (PII) like IP addresses that aren’t anonymised. Discuss this further with your DPO.

  10. Once you’ve established what data you can legally import, then you can begin the import. Follow the steps provided by your new web analytics solution provider.

  11. Remove Google Analytics tracking code from your site. This will stop the collection of your visitors data by Google as well as slightly increase the page load speed.

  If you still haven’t made a choice yet, try Matomo free for 21-days and see why over 1 million websites choose Matomo. 

• Overthinking My Search Engine Problem

  31 décembre 2013, par Multimedia Mike — General

  I wrote a search engine for my Game Music Appreciation website, because the site would have been significantly less valuable without it (and I would eventually realize that the search feature is probably the most valuable part of this endeavor). I came up with a search solution that was a bit sketchy, but worked… until it didn’t. I thought of a fix but still searched for more robust and modern solutions (where ‘modern’ is defined as something that doesn’t require compiling a C program into a static CGI script and hoping that it works on a server I can’t debug on).

  Finally, I realized that I was overthinking the problem– did you know that a bunch of relational database management systems (RDBMSs) support full text search (FTS) ? Okay, maybe you did, but I didn’t know this.

  Problem Statement
  My goal is to enable users to search the metadata (title, composer, copyright, other tags) attached to various games. To do this, I want to index a series of contrived documents that describe the metadata. 2 examples of these contrived documents, interesting because both of these games have very different titles depending on region, something the search engine needs to account for :

  system : Nintendo NES
  game : Snoopy’s Silly Sports Spectacular
  author : None ; copyright : 1988 Kemco ; dumped by : None
  additional tags : Donald Duck.nsf Donald Duck
  system : Super Nintendo
  
  game : Arcana
  
  author : Jun Ishikawa, Hirokazu Ando ; copyright : 1992 HAL Laboratory ; dumped by : Datschge
  
  additional tags : card.rsn.gamemusic Card Master Cardmaster
  

  The index needs to map these documents to various pieces of game music and the search solution needs to efficiently search these documents and find the various game music entries that match a user’s request.

  Now that I’ve been looking at it for long enough, I’m able to express the problem surprisingly succinctly. If I had understood that much originally, this probably would have been simpler.

  First Solution & Breakage
  My original solution was based on SWISH-E. The CGI script was a C program that statically linked the SWISH-E library into a binary that miraculously ran on my web provider. At least, it ran until it decided to stop working a month ago when I added a new feature unrelated to search. It was a very bizarre problem, the details of which would probably bore you to tears. But if you care, the details are all there in the Stack Overflow question I asked on the matter.

  While no one could think of a direct answer to the problem, I eventually thought of a roundabout fix. The problem seemed to pertain to the static linking. Since I couldn’t count on the relevant SWISH-E library to be on my host’s system, I uploaded the shared library to the same directory as the CGI script and used dlopen()/dlsym() to fetch the functions I needed. It worked again, but I didn’t know for how long.

  Searching For A Hosted Solution
  I know that anything is possible in this day and age ; while my web host is fairly limited, there are lots of solutions for things like this and you can deploy any technology you want, and for reasonable prices. I figured that there must be a hosted solution out there.

  I have long wanted a compelling reason to really dive into Amazon Web Services (AWS) and this sounded like a good opportunity. After all, my script works well enough ; if I could just find a simple Linux box out there where I could install the SWISH-E library and compile the CGI script, I should be good to go. AWS has a free tier and I started investigating this approach. But it seems like a rabbit hole with a lot of moving pieces necessary for such a simple task.

  I had heard that AWS had something in this area. Sure enough, it’s called CloudSearch. However, I’m somewhat discouraged by the fact that it would cost me around $75 per month to run the smallest type of search instance which is at the core of the service.

  Finally, I came to another platform called Heroku. It’s supposed to be super-scalable while having a free tier for hobbyists. I started investigating FTS on Heroku and found this article which recommends using the FTS capabilities of their standard hosted PostgreSQL solution. However, the free tier of Postgres hosting only allows for 10,000 rows of data. Right now, my database has about 5400 rows. I expect it to easily overflow the 10,000 limit as soon as I incorporate the C64 SID music corpus.

  However, this Postgres approach planted a seed.

  RDBMS Revelation
  I have 2 RDBMSs available on my hosting plan– MySQL and SQLite (the former is a separate service while SQLite is built into PHP). I quickly learned that both have FTS capabilities. Since I like using SQLite so much, I elected to leverage its FTS functionality. And it’s just this simple :

  CREATE VIRTUAL TABLE gamemusic_metadata_fts USING fts3
  ( content TEXT, game_id INT, title TEXT ) ;
  SELECT id, title FROM gamemusic_metadata_fts WHERE content MATCH "arcana" ;
  
  479|Arcana
  

  The ‘content’ column gets the metadata pseudo-documents. The SQL gets wrapped up in a little PHP so that it queries this small database and turns the result into JSON. The script is then ready as a drop-in replacement for the previous script.

• Lawful basis for processing personal data under GDPR with Matomo

  30 avril 2018, par InnoCraft

  Disclaimer : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to explain what is a lawful basis and which one you can use with Matomo in order to be GDPR compliant. This work comes from our interpretation of the following web page from the UK privacy commission : ICO. It cannot be considered as professional legal advice. So as GDPR, this information is subject to change. GDPR may be also known as DSGVO in German, BDAR in Lithuanian, RGPD in Spanish, French, Italian, Portuguese. This blog post contains public sector information licensed under the Open Government Licence v3.0.

  The golden rule under GDPR is that you need to have a lawful basis in order to process personal data. Note that it is possible to not process personal data with Matomo. When you do not collect any personal data, then you do not need to determine a lawful basis and this article wouldn’t apply to you.

  “If no lawful basis applies to your processing, your processing will be unlawful and in breach of the first principle.“

  Source : ICO, based on article 6 of GDPR.

  As you may process personal data in Matomo, you have to :

  1. define a lawful basis.
  2. document your choice.
  3. inform your visitor about it in a privacy notice.

  Even if you think you don’t process personal data, we recommend reading this post about personal data in Matomo (personal data may be hidden in many ways).

  Note that if you are processing special category data (ethnic origin, politics, religion, trade union membership…) or criminal offence data ; extra responsibilities are applied, and we will not detail them in this blog post.

  1 – Define a lawful basis

  There are 6 different lawful bases all defined within article 6 of the GDPR official text :

  1. Consent : the data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  2. Contract : processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  3. Legal obligation : processing is necessary for compliance with a legal obligation to which the controller is subject.
  4. Vital interests : processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  5. Public task : processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in the controller.
  6. Legitimate interests : processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party ; except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

  As you can see, most of them are not applicable to Matomo. As ICO is mentioning it within their documentation :

  “In many cases you are likely to have a choice between using legitimate interests or consent.”

  “Consent” or “Legitimate interests” : which lawful basis is the best when using Matomo ?

  Well, there is no right or wrong answer here.

  In order to make this choice, ICO listed on their website different questions you should keep in mind :

  • Who does the processing benefit ?
  • Would individuals expect this processing to take place ?
  • What is your relationship with the individual ?
  • Are you in a position of power over them ?
  • What is the impact of the processing on the individual ?
  • Are they vulnerable ?
  • Are some of the individuals concerns likely to object ?
  • Are you able to stop the processing at any time on request ?

  From our perspective, “Legitimate interests” should be used in most of the cases as :

  • The processing benefits to the owner of the website and not to a third party company.
  • A user expects to have their data kept by the website itself.
  • Matomo provides many features in order to show how personal data is processed and how users can exercise their rights.
  • As the data is not used for profiling, the impact of processing personal data is very low.

  But once more, it really depends ; if you are processing personal data which may represent a risk to the final user, then getting consent is for us the right lawful basis.

  If you are not sure, at the time of writing ICO is providing a tool in order to help you make this decision :

  

  Note that once you choose a lawful basis, it is highly recommended not to switch to another unless you have a good reason.

  What are the rights that a data subject can exercise ?

  According to the lawful basis you choose for processing personal data with Matomo, your users will be able to exercise different rights :

  	Right to be informed	Right of access	Right to erasure	Right to portability	Right to object	Right to withdraw consent
  Legitimate interests	X	X	X		X
  Consent	X	X	X	X		X

   

  • Right to be informed : whatever the lawful basis you choose, you need to inform your visitor about it within your privacy notice.
  • Right of access : as described in article 15 of GDPR. Your visitor has the right to access the personal data you are processing about them. You can exercise their right directly within the page “GDPR Tools” in your Matomo.
  • Right to erasure : it means that a visitor will be able to ask you to erase all their data. You can exercise the right to erasure directly within the page “GDPR Tools” in your Matomo.
  • Right to portability : it means that you need to export the data which concern the individual in a machine-readable format and provide them with their personal data. You can exercise their right directly within the page “GDPR Tools” in your Matomo.
  • Right to object : it means that your visitor has the right to say no to the processing of their personal data. In order to exercise this right, you need to implement the opt-out feature on your website.
  • Right to withdraw consent : it means that your visitor can remove their consent at any time. We developed a feature in order to do just that. You can learn more by opening the page “Privacy > Asking for consent” in your Matomo.

  2 – Document your choice

  Once you choose “Legitimate interests” or “Consent” lawful basis, you will have some obligations to fulfill. From our interpretation, “Legitimate interests” means writing more documentation, “Consent” means a more technical approach.

  What should I do if I am processing personal data with Matomo based on “Legitimate interests ?

  ICO is providing a checklist for “Legitimate interests”, below is our interpretation :

  • Check that legitimate interests is the most appropriate lawful basis.

  Our interpretation : document and justify why you choose this lawful basis in particular. This tool from ICO can help you.

  • Understand your responsibility to protect the individual’s interests.

  Our interpretation : you need to take all the measures in order to protect your users privacy and data security. Please refer to our guide in order to secure your Matomo installation.

  • Conduct a legitimate interests assessment (LIA) and keep a record of it to ensure that you can justify your decision. This document is composed of a set of questions on those 3 key concerns : 1) purpose, 2) necessity, 3) balancing.

  1) Purpose :

  • Why do you want to process the data – what are you trying to achieve ?
  • Who benefits from the processing ? In what way ?
  • Are there any wider public benefits to the processing ?
  • How important are those benefits ?
  • What would the impact be if you couldn’t go ahead ?
  • Would your use of the data be unethical or unlawful in any way ?

  2) Necessity :

  • Does this processing actually help to further that interest ?
  • Is it a reasonable way to go about it ?
  • Is there another less intrusive way to achieve the same result ?

  3) Balancing :

  • What is the nature of your relationship with the individual ?
  • Is any of the data particularly sensitive or private ?
  • Would people expect you to use their data in this way ?
  • Are you happy to explain it to them ?
  • Are some people likely to object or find it intrusive ?
  • What is the possible impact on the individual ?
  • How big an impact might it have on them ?
  • Are you processing children’s data ?
  • Are any of the individuals vulnerable in any other way ?
  • Can you adopt any safeguards to minimise the impact ?
  • Can you offer an opt-out ?

  • Identify the relevant legitimate interests.
  • Check that the processing is necessary and there is no less intrusive way to achieve the same result.
  • Perform a balancing test, and be confident that the individual’s interests do not override those legitimate interests.
  • Use individuals’ data in ways they would reasonably expect, unless you have a very good reason.

  Our interpretation : use those data to improve user experience for example.

  • Do not use people’s data in ways they would find intrusive or which could cause them harm, unless you have a very good reason.

  Our interpretation : ask yourself if this data is representing a risk for the individuals.

  • If you process children’s data, take extra care to make sure you protect their interests.
  • Consider safeguards to reduce the impact where possible.

  Our interpretation : Check if your web hosting provider is providing appropriate safeguards.

  • Consider whether you can offer an opt out.

  Our interpretation : Matomo is providing you the opt-out feature.

  • If your LIA identifies a significant privacy impact, consider whether you also need to conduct a DPIA.

  Our interpretation : A DPIA can easily be conducted by using this software from the French privacy commission.

  • Regularly review your LIA and update it when circumstances change.
  • Include information about your legitimate interests in your privacy information.

  As you see, going for “Legitimate interests” requires a lot of written documentation. Let’s see how “Consent” differ.

  What should I do if I am processing personal data with Matomo based on “Consent” ?

  As previously mentioned, using “Consent” rather than “Legitimate interests” is more technical but less intense in terms of documentation. Like for “Legitimate interests”, ICO is providing a checklist for “Consent” which is divided into 3 key categories : 1) asking for consent, 2) recording consent, and 3) managing consent.

  1. Asking for consent :
     1. Check that consent is the most appropriate lawful basis for processing.
     2. Make the request for consent prominent and separate from your terms and conditions.
     3. Ask people to positively opt in. Don’t use pre-ticked boxes or any other type of default consent.
     4. Use clear, plain language that is easy to understand.
     5. Specify why you want the data and what you are going to do with it.
     6. Give individual (‘granular’) options to consent separately to different purposes and types of processing.
     7. Name your organisation and any third party controllers who will be relying on the consent.
     8. Tell individuals they can withdraw their consent.
     9. Ensure that individuals can refuse to consent without detriment.
     10. Avoid making consent a precondition of a service.
     11. If you offer online services directly to children, only seek consent if you have age-verification measures (and parental-consent measures for younger children) in place.
  2. Recording consent :
     1. Keep a record of when and how you got consent from the individual.
     2. Keep a record of exactly what you told them at the time.
  3. Managing consent :
     1. Regularly review consents to check that the relationship, the processing and the purposes have not changed.
     2. Have processes in place to refresh consent at appropriate intervals, including any parental consent.
     3. Consider using privacy dashboards or other preference-management tools as a matter of good practice.
     4. Make it easy for individuals to withdraw their consent at any time, and publicise how to do so.
     5. Act on withdrawals of consent as soon as you can.
     6. Don’t penalise individuals who wish to withdraw consent.

     3 – Inform your visitor about it in a privacy notice

     Privacy notices are an important part within the GDPR process. Read our blog post dedicated to privacy notices to learn more.

     We really hope you enjoyed reading this blog post. Please have a look at our Matomo GDPR guide for more information.

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